Memorandum for the Petitioners |150 human dignity; and the protection of human requires averting catastrophic climate change.®”° dignity A.4. Findings concerning respondent Carbon Majors’ knowledge and actions and/or inactions in light of foreseeable climate risks a) At all relevant times, the respondent Carbon Majors can and should be presumed to be experts in all aspects of the products they produced, manufactured, marketed or otherwise put into the stream of commerce;°* b) The fossil fuel industry was or should have been aware that fossil fuel combustion could alter the global climate by the early 20th century;®” c) By no later than the 1960s, the fossil fuel industry was actively engaging in climate science and had actual knowledge of the grave dangers posed to people by climate change arising from the use of their fossil fuel products;°” d) In the 1970s, the fossil fuel industry began to publicly question the legitimacy of climate science, as a business tactic, while internally their own scientists repeatedly warned of climate risks; e) By the 1980s, the fossil fuel industry knew there was broad scientific consensus that climate change was real, was caused by fossil fuel consumption, and would have significant impacts on the environment and human rights;7° f) In the 1990s, following the establishment of the IPCC and the start of the global climate negotiations, the fossil fuel industry ran full blown campaigns that manufactured doubt about climate science, concealed the foreseeable human impacts of using fossil fuel products, and delayed meaningful action;”! 65 Daly, E., TSN dated 27-28 September 2018, supra note 379. 696 Exhibit “GGGGG” to “GGGGG-35,” Profile and Statement of Carroll Muffet, supra note 141. 697 Part V (D), p. 41. 6°8 Part V (D), pp. 41-46. 69 Part V (D), pp. 46-48. 0 Part V (D), pp. 48-52. 7! Part V (D), pp. 52-59.