Notice2025-06564
Petition of Chevron Corporation and Hess Corporation To Reopen and Set Aside Order
Primary source
Metadata and text below are from the Federal Register, a public-domain U.S. government work. Always verify the official published version before relying on it for any legal matter.
Published
April 17, 2025
Issuing agencies
Federal Trade Commission
Abstract
Chevron Corporation and Hess Corporation (collectively, the "Respondents"), have asked the Federal Trade Commission ("FTC" or "Commission") to reopen and set aside the Commission's Decision and Order entered on January 17, 2025, concerning Chevron's acquisition of Hess. Publication of Respondents' petition is not intended to affect its legal status or its final disposition.
Full Text
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<title>Federal Register, Volume 90 Issue 73 (Thursday, April 17, 2025)</title>
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[Federal Register Volume 90, Number 73 (Thursday, April 17, 2025)]
[Notices]
[Pages 16130-16134]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2025-06564]
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FEDERAL TRADE COMMISSION
[Docket No. C-4814]
Petition of Chevron Corporation and Hess Corporation To Reopen
and Set Aside Order
AGENCY: Federal Trade Commission.
ACTION: Announcement of petition; request for comment.
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SUMMARY: Chevron Corporation and Hess Corporation (collectively, the
``Respondents''), have asked the Federal Trade Commission (``FTC'' or
``Commission'') to reopen and set aside the Commission's Decision and
Order entered on January 17, 2025, concerning Chevron's acquisition of
Hess. Publication of Respondents' petition is not intended to affect
its legal status or its final disposition.
DATES: Comments must be received on or before May 12, 2025.
ADDRESSES: Interested parties may file comments online or on paper, by
following the instructions in the Request for Comment part of the
SUPPLEMENTARY INFORMATION section below. Please write: ``Chevron/Hess
Petition to Reopen; Docket No. C-4814'' on your comment and file your
comment online at <a href="https://www.regulations.gov/docket/FTC-2025-0029/document">https://www.regulations.gov/docket/FTC-2025-0029/document</a> by following the instructions on the web-based form. If you
prefer to file your comment on paper, please mail your comment to the
following address: Federal Trade Commission, Office of the Secretary,
600 Pennsylvania Avenue NW, Mail Stop H-144 (Annex O), Washington, DC
20580.
FOR FURTHER INFORMATION CONTACT: Peter Richman (202-326-2563), Bureau
of Competition, Federal Trade Commission, 600 Pennsylvania Avenue NW,
Washington, DC 20580.
SUPPLEMENTARY INFORMATION: Pursuant to section 6(g) of the Federal
Trade Commission Act, 15 U.S.C. 46(g), and FTC Rule 2.51, 16 CFR 2.51,
notice is hereby given that the above-captioned petition has been filed
with the Secretary of the Commission and is being placed on the public
record for a period of 30 days. After the period for public comments
has expired and no later than 120 days after the date of the filing of
the request, the Commission shall determine whether to reopen the
proceeding and modify the Order as requested. In making its
determination, the Commission will consider, among other information,
all timely and responsive comments submitted in connection with this
notification.
[[Page 16131]]
The text of the petition is provided below. An electronic copy of
the filed petition and any public exhibits attached to it can be
obtained from the FTC website at this URL: <a href="https://www.ftc.gov/legal-library/browse/cases-proceedings/241-0008-chevronhess-matter">https://www.ftc.gov/legal-library/browse/cases-proceedings/241-0008-chevronhess-matter</a>.
You can file a comment online or on paper. For the Commission to
consider your comment, we must receive it on or before May 12, 2025.
Write ``Chevron/Hess Petition to Reopen; Docket No. C-4814'' on your
comment. Your comment--including your name and your State--will be
placed on the public record of this proceeding, including, to the
extent practicable, on the <a href="http://www.regulations.gov">www.regulations.gov</a> website.
Because of the agency's heightened security screening, postal mail
addressed to the Commission will be subject to delay. We strongly
encourage you to submit your comments online through the
<a href="http://www.regulations.gov">www.regulations.gov</a> website. If you prefer to file your comment on
paper, write ``Chevron/Hess Petition to Reopen; Docket No. C-4814'' on
your comment and on the envelope, and mail your comment to the
following address: Federal Trade Commission, Office of the Secretary,
600 Pennsylvania Avenue NW, Mail Stop H-144 (Annex O), Washington, DC
20580. If possible, submit your paper comment to the Commission by
overnight service.
Because your comment will be placed on the publicly accessible
website at <a href="http://www.regulations.gov">www.regulations.gov</a>, you are solely responsible for making
sure that your comment does not include any sensitive or confidential
information. In particular, your comment should not include any
sensitive personal information, such as your or anyone else's Social
Security number; date of birth; driver's license number or other State
identification number, or foreign country equivalent; passport number;
financial account number; or credit or debit card number. You are also
solely responsible for making sure your comment does not include any
sensitive health information, such as medical records or other
individually identifiable health information. In addition, your comment
should not include any ``trade secret or any commercial or financial
information which . . . is privileged or confidential''--as provided by
section 6(f) of the FTC Act, 15 U.S.C. 46(f), and FTC Rule 4.10(a)(2),
16 CFR 4.10(a)(2)--including in particular competitively sensitive
information such as costs, sales statistics, inventories, formulas,
patterns, devices, manufacturing processes, or customer names.
Comments containing material for which confidential treatment is
requested must be filed in paper form, must be clearly labeled
``Confidential,'' and must comply with FTC Rule 4.9(c). In particular,
the written request for confidential treatment that accompanies the
comment must include the factual and legal basis for the request and
must identify the specific portions of the comment to be withheld from
the public record. See FTC Rule 4.9(c). Your comment will be kept
confidential only if the General Counsel grants your request in
accordance with the law and the public interest. Once your comment has
been posted on <a href="http://www.regulations.gov">www.regulations.gov</a>--as legally required by FTC Rule
4.9(b)--we cannot redact or remove your comment from that website,
unless you submit a confidentiality request that meets the requirements
for such treatment under FTC Rule 4.9(c), and the General Counsel
grants that request.
Visit the FTC website at <a href="https://www.ftc.gov">https://www.ftc.gov</a> to read this document
and the news release describing this matter. The FTC Act and other laws
that the Commission administers permit the collection of public
comments to consider and use in this proceeding, as appropriate. The
Commission will consider all timely and responsive public comments that
it receives on or before May 12, 2025. For information on the
Commission's privacy policy, including routine uses permitted by the
Privacy Act, see <a href="https://www.ftc.gov/site-information/privacy-policy">https://www.ftc.gov/site-information/privacy-policy</a>.
Authority: 15 U.S.C. 46, 5 U.S.C. 552.
April J. Tabor,
Secretary.
Text of Petition by Chevron Corporation and Hess Corporation To Reopen
and Set Aside the Order
Pursuant to section 5(b) of the Federal Trade Commission Act, 15
U.S.C. 45(b), and section 2.51 of the Federal Trade Commission Rules of
Practice, 16 CFR 2.51, Respondents Chevron Corporation (``Chevron'')
and Hess Corporation (``Hess'') (collectively, the ``Respondents'')
respectfully request that the Commission reopen and set aside the
Commission's Decision and Order entered on January 17, 2025,\1\ in
Docket No. C-4814 (the ``Order'').
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\1\ The Order was issued on January 16, 2025, and final when
received by the Respondents on January 17, 2025. See 16 CFR 2.34(c).
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The Order bars Chevron from nominating, designating or appointing
Hess CEO John B. Hess from joining Chevron's Board of Directors, as is
required by the Respondents' merger agreement.\2\ A divided Commission
voted to issue a Complaint alleging that Mr. Hess's appointment to the
Chevron Board ``would heighten the risk of harm to competition,
including meaningfully increasing the risk of industry coordination''
in the global market for the development, production, and sale of crude
oil.\3\ As set forth below, and as made clear in Chairman Ferguson's
and Commissioner Holyoak's September 30, 2024 dissenting statements,
the Commission's Complaint failed to state a cognizable theory of
competitive harm under section 7 of the Clayton Act, as amended, 15
U.S.C. 18, or section 5 of the Federal Trade Commission Act, 15 U.S.C.
45, under which to challenge the Chevron/Hess merger.\4\ The
Respondents hereby respectfully petition the Commission to reopen and
set aside the Order in the public interest.
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\2\ See Decision and Order, In the Matter of Chevron Corp. &
Hess Corp., File No. 241-0008 (Jan. 16, 2025), ] II.A. The Order
also prohibits Chevron from appointing Mr. Hess to serve in an
advisory or consultative capacity to Chevron or its board, with
limited exceptions. Id. at ] II.B.
\3\ See Complaint, In the Matter of Chevron Corp. & Hess Corp.,
File No. 241-0008 (Jan. 16, 2025), ]] 19-20, 50.
\4\ See generally Dissenting Statement of Commissioner Andrew N.
Ferguson, In the Matter of Chevron Corp. & Hess Corp., File No. 241-
0008 (Sep. 30, 2024) (the ``Ferguson Dissent''); Dissenting
Statement of Commissioner Melissa Holyoak, In the Matter of Chevron
Corp. & Hess Corp., File No. 241-0008 (Sep. 30, 2024) (the ``Holyoak
Dissent''). While Commissioners Holyoak and Ferguson did not issue
separate written dissents to the Commission's January 17, 2025 final
Decision and Order, their dissents are incorporated into the final
order, and they are referenced in Commissioner Holyoak's written
dissent to the Commission's contemporaneous final Decision and Order
for the ExxonMobil matter. See Dissenting Statement of Commissioner
Melissa Holyoak Joined by Commissioner Andrew N. Ferguson, In the
Matter of ExxonMobil/Pioneer Res., Final Decision and Order, File
No. 241-0004 (Jan. 17, 2025), at 1 n.3 (``I also voted today to
reject the finalization of the Decision and Order that resolves the
merger of Chevron and Hess. . . . My views have not changed with
respect to the flawed nature of the complaint and consent in
Chevron/Hess--views that continue to apply to my decision to vote
against today's finalization of the Decision and Order [in the
matter of ExxonMobil].'').
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I. Background
A. Merger Transaction
On October 22, 2023, the Respondents entered into an Agreement and
Plan of Merger (the ``Merger Agreement'') pursuant to which Chevron
will acquire Hess. As consideration for the merger, Hess shareholders
will receive shares of Chevron voting securities with an aggregate
value of approximately $53 billion at signing. Among other things,
Section 1.3(a) of the Merger Agreement requires Chevron and its Board
of Directors, upon closing of the proposed
[[Page 16132]]
merger, to take all actions necessary to increase the size of the
Chevron Board from twelve to thirteen members and to appoint Mr. Hess
as a Chevron director. Upon closing of the merger, Hess's shareholders
will hold in the aggregate approximately 15 percent of Chevron's
outstanding voting securities, and the covenant to appoint Mr. Hess to
Chevron's Board is consistent with board representation for those
shareholders, as well as with their expectations when they voted to
approve the merger. Mr. Hess's appointment to Chevron's Board is also
consistent with Chevron's communications to Hess before the Merger
Agreement was signed, in which Chevron conveyed its desire that Mr.
Hess join the Chevron Board upon the closing of the merger. Chevron's
commitment to appoint Mr. Hess as one of thirteen members of the
Chevron Board is a fundamental part of the overall merger transaction.
The Respondents have not yet closed the merger. On May 28, 2024,
holders of a majority of Hess's outstanding common stock voted to
approve the merger. Hess Guyana Exploration Limited (``HGEL''), a
wholly owned subsidiary of Hess, is currently in arbitration relating
to the applicability of a right of first refusal (the ``Stabroek
ROFR'') contained in the operating agreement among HGEL and affiliates
of Exxon Mobil Corporation and China National Offshore Oil Corporation
to the merger. An arbitration merits hearing about the applicability of
the Stabroek ROFR to the merger has been scheduled for May 2025, with a
decision expected in the following three months.
B. The Order
On January 17, 2025, on the last Federal working day before the
change of administrations, the Commission finalized the Order following
a 3-to-2 vote. The Order bars Chevron from nominating, designating, or
appointing Mr. Hess to the Chevron Board, or allowing Mr. Hess to serve
in an advisory or consulting capacity to, or as a representative of,
Chevron or the Chevron Board, other than with respect to interactions
and discussions with (a) Guyanese government officials about Hess's
oil-related and health ministry-related activities in Guyana, and (b)
the Salk Institute's Harnessing Plants Initiative.
By its terms, the Order will terminate in ten years. Unless set
aside, the Order will preclude Chevron from fulfilling its contractual
obligation to appoint Mr. Hess to the Chevron board upon closing of the
merger, and deprive shareholders of the benefit of his service.
The Respondents acknowledge that a majority of the prior Commission
voted to issue the Order pursuant to an Agreement Containing Consent
Order among Chevron, Hess, and the Commission staff (the ``ACCO''). The
Respondents did not sign the ACCO because they agreed with the prior
Commission's characterization of the facts, or with its interpretation
and application of section 7 or section 5 to those facts. As explicitly
noted in the document, the ACCO was ``for settlement purposes only and
does not constitute an admission . . . that the law has been violated
as alleged in the Draft Complaint, or that the facts as alleged in the
Draft Complaint, other than jurisdictional facts, are true.'' \5\
Chevron and Hess entered into the ACCO solely to satisfy a key closing
condition to their Merger Agreement, and thereby to reduce uncertainty
and facilitate a more prompt closing of the proposed transaction, in
the best interest of each company's shareholders. As noted in the
Ferguson Dissent, in getting the Respondents to agree to the ACCO,
``[t]he Commission leveraged its Hart-Scott-Rodino Act authority by
threatening to hold up Chevron and Hess's $53 billion merger even
though the lack of a plausible section 7 theory had long been
obvious.'' \6\ That the Respondents acceded to this leverage should not
factor into the Commission's decision whether to reopen and set aside
this Order.
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\5\ Agreement Containing Consent Order, In the Matter of Chevron
Corp. & Hess Corp., File No. 241-0008 (Sept. 23, 2024), at ] 5.
\6\ Ferguson Dissent at 5-6 (citation omitted).
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C. The Respondents' Compliance With the Order
Chevron has been in compliance with the Proposed Decision and Order
contained in the ACCO since it was executed on September 23, 2024, and
with the Order since it was finalized on January 17, 2025, as reflected
in the required compliance reports filed by Chevron on October 23,
2024; November 22, 2024; December 20, 2024; and March 17, 2025.
II. The Commission Should Reopen and Set Aside the Order in the Public
Interest
Respondents subject to a Commission decision containing an order
which has become effective may file a request that the Commission
reopen the proceeding to consider whether the order should be altered,
modified, or set aside in whole or in part, if the public interest
requires it.\7\
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\7\ See 16 CFR 2.51.
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Here, public interest in the effective enforcement of the antitrust
laws, as well as in the continued investment in oil and gas production
championed by Mr. Hess, is best served by setting aside the Order and
allowing Mr. Hess to join Chevron's Board.
A. Setting Aside the Order Serves the Public Interest in the Effective
Enforcement of the Antitrust Laws, as the Complaint Failed To State a
Cognizable Theory of Harm Under Section 7 or Section 5
Section 7 prohibits acquisitions the effect of which ``may be
substantially to lessen competition, or to tend to create a monopoly,''
\8\ and section 5 declares unlawful ``unfair methods of competition in
or affecting commerce.'' \9\ As noted in the Holyoak Dissent, the
Complaint ``does not take issue with Chevron's acquisition of Hess
Corporation's assets. Nor could it.'' \10\ The Respondents' combined
share in the global market for oil and gas is in the low single digits,
and Hess's incremental portion of that share--what Hess will add to
Chevron post-close--is de minimis. Even under the agencies' 2023 Merger
Guidelines, the Respondents' combined share is far below the level at
which a merger could be presumed to harm competition. The fact that the
prior Commission, after its months-long investigation into the
Respondents' operations, allowed the merger to proceed without any
structural or behavioral remedies demonstrates that there are no
anticompetitive grounds on which to challenge the combination of these
two companies. That fact was amplified by Senator Mike Lee and
Congressman Jim Jordan in their November 18, 2024 joint letter to
former Chair Khan: ``These mergers did not present any anticompetitive
concerns, thus the FTC's consent decrees are unwarranted and did
nothing to enforce the Clayton Act or protect consumers from
anticompetitive harm.'' \11\
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\8\ 15 U.S.C. 18.
\9\ 15 U.S.C. 45(a)(1).
\10\ Holyoak Dissent at 2.
\11\ Letter from Sen. Mike Lee and Congressman Jim Jordan to
Chair Lina Khan (Nov. 18, 2024), at 2, <a href="https://judiciary.house.gov/sites/evo-subsites/republicans-judiciary.house.gov/files/evo-media-document/2024-11-18%20JDJ%20Lee%20to%20Khan%20re%20Exxon%20Pioneer%20Chevron%20Hess%20briefing.pdf">https://judiciary.house.gov/sites/evo-subsites/republicans-judiciary.house.gov/files/evo-media-document/2024-11-18%20JDJ%20Lee%20to%20Khan%20re%20Exxon%20Pioneer%20Chevron%20Hess%20briefing.pdf</a>.
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Rather, the prior Commission relied on a novel theory on which to
extract a concession from the parties, focused not on the two
companies' asset footprints and oil and gas production, but rather on
the appointment of Mr. Hess to Chevron's Board of Directors.
[[Page 16133]]
Pointing to certain communications by Mr. Hess with Organization of the
Petroleum Exporting Countries (``OPEC'') officials and a representative
of an OPEC member State--but without alleging any improper collusion--
the Commission alleged that, through the merger, Mr. Hess would have
access to Chevron's ``broader platform'' from which to continue such
communications, and in turn increase the likelihood that Chevron would
collude with OPEC regarding the supply and price of oil and gas.
This allegation fails to state a cognizable antitrust theory of
harm. As highlighted in the Holyoak Dissent,
Nothing in the complaint alleges that Mr. Hess has ever attempted
to, or coordinated with, a rival.
* * * * *
Taking the allegations and the implications against Mr. Hess as
true, neither he nor Hess Corporation ever coordinated or attempted to
coordinate with Hess Corporation's rivals.\12\
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\12\ Holyoak Dissent at 2, 4.
Given that fact, there is no basis under the 2023 Merger Guidelines
to conclude the proposed merger would violate section 7 or section 5
under a coordinated effects theory of competitive harm. But as also
noted in the Holyoak Dissent, ``the tangible and intangible assets of
Hess Corporation have nothing to do with the violation of law [alleged
in the prior Commission's complaint]--it's all about the acquisition of
Mr. Hess.'' This theory of harm, Commissioner Holyoak notes, is
``farcical'' and one that ``[c]ertainly no court would endorse.'' \13\
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\13\ Id. at 2.
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Even were the Respondents to accept that this is a plausible theory
of harm under section 7, it fails on its own terms. As highlighted in
the Ferguson Dissent, this theory assumes that: (i) Chevron would allow
Mr. Hess to continue such communications post-closing of the
transaction; (ii) that such communication is made worse by the
transaction--a transaction through which Mr. Hess's role would be
reduced from CEO and significant shareholder (as he currently is in
Hess Corporation) to non-executive member of a thirteen-person Board
(as he would be at Chevron post-merger); and (iii) that this conduct
would have a significant effect on global oil prices, which, as stated
above, is implausible given the Respondents' low combined shares and
lack of any coordinated behavior or sharing of competitively sensitive
information. The Complaint provides no justification for any of these
three assumptions.
While the former Chair touted the withdrawal of Mr. Hess's
nomination to the Chevron Board in exchange for clearance of the
Respondents' merger in a list of Commission Accomplishments achieved
under her tenure,\14\ the Ferguson Dissent rightly notes that this
settlement ``does not vindicate the rule of law,'' but rather serves to
further reduce antitrust enforcement to a ``pay-for-peace racket
inflict[ing] serious injury on the rule of law--and on the Commission's
credibility.'' \15\ Preserving the Commission's credibility is
paramount to the public interest in the effective enforcement of the
antitrust laws, and this interest is best served by setting aside the
Order in recognition of the Complaint's deficiencies.
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\14\ Federal Trade Commission Accomplishments, June 2021-January
2025 (Jan. 19, 2025), at 16, <a href="https://www.ftc.gov/system/files/ftc_gov/pdf/ftc-accomplishments-june-2021-january-2025.pdf">https://www.ftc.gov/system/files/ftc_gov/pdf/ftc-accomplishments-june-2021-january-2025.pdf</a> (claiming
the Order and the ExxonMobil/Pioneer settlement ``[a]dvanced the
increased risk of coordination as a basis for Section 7
liability'').
\15\ Ferguson Dissent at 6, 7.
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B. The Public Interest in Continued Investment in Oil and Gas Supply Is
Served by Setting Aside the Order
In addition to the public's interest in the just enforcement of the
antitrust laws, there is a significant public interest in continued
investment in oil and gas supply. Ensuring that U.S. oil and gas
producers can meet expected increases in consumer demand for energy is
vital to the interest of consumers, downstream industries that rely on
oil and gas production, as well as U.S. national and energy
security.\16\
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\16\ See Exec. Order No. 14156, 90 FR 8433, 8433 (Jan. 29,
2025), <a href="https://www.federalregister.gov/documents/2025/01/29/2025-02003/declaring-a-national-energy-emergency">https://www.federalregister.gov/documents/2025/01/29/2025-02003/declaring-a-national-energy-emergency</a> (``The integrity and
expansion of our Nation's energy infrastructure--from coast to
coast--is an immediate and pressing priority for the protection of
the United States' national and economic security.'').
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Mr. Hess has spent his career advocating for such an increase in
investment to grow oil and gas supply, for the benefit of consumers,
workers, and U.S. energy security. Throughout his career, Mr. Hess has
been recognized as an industry authority on energy policy. He has been
called on to advise U.S. administrations on their energy policy,
including as an informal advisor to members of the cabinets of
Presidents Clinton, Bush, Obama, Biden, and Trump.
As CEO of Hess, Mr. Hess has put this advocacy for greater
investment into practice. Under Mr. Hess's leadership, Hess has
differentiated itself from its peers with the highest levels of cash
flow reinvestment in the industry in order to increase future oil and
gas supply. This prioritization of reinvestment for long-term
production growth is manifest in Hess's global production of oil and
gas, which grew from 101 million barrels of oil equivalent in 2018 to
144 million barrels in 2023, an increase of nearly 45 percent.\17\ This
reinvestment strategy is projected to yield further robust growth in
the near-term: a recent Bloomberg analyst consensus projects Hess will
achieve a 14 percent compound annual growth rate (``CAGR'') over the
years 2023 to 2025, compared to the median cohort CAGR of two
percent.\18\ This projected organic growth rate is approximately double
that of Hess's closest peer, and is multiples of that of U.S. major oil
and gas producers. Hess, under Mr. Hess's leadership, has chosen to
invest its capital in future oil and gas production for the long term,
rather than return capital to shareholders.
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\17\ Hess Corp., 2020 Annual Report (Mar. 2021), at 7, <a href="https://investors.hess.com/static-files/0869f80e-06ec-419d-b18a-b51d34968c44">https://investors.hess.com/static-files/0869f80e-06ec-419d-b18a-b51d34968c44</a>; Hess Corp., 2023 Annual Report (Feb. 2024), at 12,
<a href="https://investors.hess.com/static-files/64c3f1e7-08e2-40b1-9190-ca2492e17343">https://investors.hess.com/static-files/64c3f1e7-08e2-40b1-9190-ca2492e17343</a>.
\18\ These data are based on FactSet, Enverus, and Bloomberg
consensus estimates as of July 8, 2024. The 2023-2025 production
growth estimates are pro forma for announced mergers, acquisitions,
and divestitures per public company disclosures.
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This record shows Mr. Hess's longstanding commitment in investing
to grow long-term oil and gas supply; it is this same commitment that
first led Chevron to propose his appointment to the Chevron Board under
the Merger Agreement, and that would make Mr. Hess an asset to the
Chevron Board. At this vital moment when the administration looks to
expand oil and gas production, it is in the public interest that Mr.
Hess be allowed to continue this work.
III. Conclusion
The Respondents agree with Chairman Ferguson that ``[n]othing in
[s]ection 7 requires Mr. Hess to stay off the Chevron board.'' \19\
Consistent with the discussion above, the Respondents respectfully
request that the Commission reopen and set aside the Order. Setting
aside the Order is consistent with the public interest in the
Commission's appropriate and effective enforcement of the antitrust
laws, and will promote long-term capital investments to grow American
oil and gas supplies.
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\19\ Ferguson Dissent at 6-7.
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Dated: March 27, 2025.
Respectfully submitted,
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Nelson O. Fitts,
[[Page 16134]]
Wachtell, Lipton, Rosen & Katz, 51 West 52nd Street, New York, New
York 10019, Attorney for Respondent Hess Corporation.
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David A. Higbee,
A&O Shearman, 1101 New York Avenue NW, Washington, DC 20005,
Attorney for Respondent Chevron Corporation.
[FR Doc. 2025-06564 Filed 4-16-25; 8:45 am]
BILLING CODE 6750-01-P
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This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.