According to the Complaint, Exxon Mobil Corporation explores for and produces crude oil and natural gas in the U.S. and abroad. One of the Company’s most important oil and gas properties is in the Permian Basin, which is currently the highest-producing oil field in the U.S. In 2017, the Company acquired acreage in the Permian Basin, in an area called the Delaware Basin, for $6.6 billion.

The Complaint alleges that throughout the Class Period, Defendants made materially false and misleading statements, and failed to disclose material adverse facts about the Company's business, operational, and compliance policies. Specifically, the Complaint alleges Defendants made false and/or misleading statements and failed to disclose to investors that: (i) Exxon forced its employees to use unrealistic assumptions regarding the timelines for well drilling in the Permian Basin; (ii) the foregoing assumptions served to artificially inflate the value of the Company's well operations in the Permian Basin; (iii) the foregoing conduct, when revealed, subjected Exxon to a heightened risk of regulatory investigation and oversight; and (iv) as a result, the Company's public statements were materially false and misleading at all relevant times.

The Court issued an Order consolidating cases and appointing Lead Plaintiffs and Counsel on June 10, 2021. All future docketing was ordered to be done in the lead case 21-CV-00194.

Lead Plaintiffs filed an amended Complaint on September 10, 2021. Defendants filed a Motion to Dismiss the amended Complaint on November 24. On September 29, 2022, the Court issued an Order granting Defendants' Motion to Dismiss. Plaintiffs were given leave to amend the Complaint.

On October 31, 2022, Lead Plaintiffs filed a second amended Complaint. Defendants filed a Motion to Dismiss the second amended Complaint on November 14. On August 24, 2023, the Court issued an Order granting in part and denying in part Defendants' Motion to Dismiss.