According to the Complaint, Apache Corporation is an independent energy company that explores for, develops, and produces natural gas, crude oil, and natural gas liquids. The U.S. has historically represented nearly 60% of the Company’s production and 70% of its estimated year-end proved reserves. At all relevant times, one of the Company’s purported key “core growth areas” in the U.S. was the Permian region, a large oil-and-gas producing area in West Texas and New Mexico.