1 Colorado, and the Marcellus Shale Formation. Anadarko operates fossil fuel product production 2 and exploration activities internationally in Algeria, Ghana, Mozambique, and Columbia, among 3 others. Anadarko Petroleum Corporation is registered to do business in California and has 4 designated an agent for service of process in California. b. 5 Anadarko Petroleum Corporation is a successor-in-interest to HS Resources 6 Inc. (“HS”). HS was an energy company headquartered in San Francisco, California. It owned 7 natural gas reserves in Colorado, North Dakota, South Dakota, Montana, and along the coasts of 8 Texas and Louisiana, which it extracted and imported to California. HS was acquired by Kerr- 9 McGee Corporation in 2001. Kerr-McGee was an energy exploration and production company 10 owning oil and natural gas rights in the Gulf of Mexico, Colorado, and Utah, with its corporate 11 headquarters in Oklahoma. Anadarko Petroleum Corporation acquired Kerr-McGee Corporation 12 in 2006. 13 14 32. Occidental Entities a. Occidental Petroleum Corporation is a multinational, vertically integrated 15 energy and chemical company incorporated in the State of Delaware and with its principal place 16 of business in Houston, Texas. Occidental’s operations consist of three segments: Occidental’s 17 operations consist of three segments: (1) the exploration for, extraction of, and production of oil 18 and natural gas products; (2) the manufacture and marketing of chemicals and vinyls; and 19 (3) processing, transport, storage, purchase, and marketing of oil, natural gas, and power. 20 Occidental Petroleum Corporation is registered to do business in the State of California and has 21 designated an agent for service of process in the State of California. 22 b. Occidental Petroleum Corporation controls and has controlled 23 companywide decisions about the quantity and extent of fossil fuel production and sales, including 24 those of its subsidiaries. 25 c. Occidental Petroleum Corporation controls and has controlled 26 companywide decisions related to climate change and greenhouse gas emissions from its fossil 27 fuel products, including those of its subsidiaries. 28 SHER EDLING LLP COMPLAINT 19