g. 1 Adopting their shareholders’ concerns about Defendants’ need to protect 2 their businesses from the inevitable consequences of profiting from their 3 fossil fuel products. Over the period of 1990–2015, Defendants’ 4 shareholders proposed hundreds of resolutions to change Defendants’ 5 policies and business practices regarding climate change. These included 6 increasing renewable energy investment, cutting emissions, and performing 7 carbon risk assessments, among others. 8 162. Despite their knowledge of the foreseeable harms associated with the consumption 9 of Defendants’ fossil fuel products, and despite the existence and fossil fuel industry knowledge 10 of opportunities that would have reduced the foreseeable dangers associated with those products, 11 Defendants wrongfully and falsely promoted, campaigned against regulation of, and concealed the 12 hazards of use of their fossil fuel products. 13 H. Defendants Caused Plaintiff’s Injuries 14 163. Defendants individually and collectively extracted a substantial percentage of all 15 16 raw fossil fuels extracted globally since 1965. 164. CO2 emissions that are attributable to fossil fuels that Defendants extracted from 17 the earth and injected into the market are responsible for a substantial percentage of greenhouse 18 gas pollution since 1965. 19 165. Defendants’ individual and collective conduct—including, but not limited to, their 20 extraction, refining, and/or formulation of fossil fuel products; their introduction of fossil fuel 21 products into the stream of commerce; their wrongful promotion of their fossil fuel products and 22 concealment of known hazards associated with use of those products; and their failure to pursue 23 less hazardous alternatives available to them—is a substantial factor in causing the increase in 24 global mean sea surface temperature, marine heatwaves, harmful algal blooms, marine toxin 25 outbreaks, and related injuries, among other consequences. 26 27 166. Defendants have actually and proximately caused the increase in mean sea surface temperature, marine heatwaves, harmful algal blooms, and domoic acid outbreaks; and the 28 SHER EDLING LLP COMPLAINT 72