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TheCorporateCounsel

TheCorporateCounsel.net

A basis for research and practical guidance focusing on federal securities laws, compliance & corporate governance.

DealLawyers

DealLawyers.com

An educational service that provides practical guidance on legal issues involving public and private mergers & acquisitions, joint ventures, private equity – and much more.

CompensationStandards

CompensationStandards.com

The “one stop” resource for information about responsible executive compensation practices & disclosure.

Section16.net

Section16.net

Widely recognized as the premier online research platform providing practical guidance on issues involving Section 16 of the Securities Exchange Act of 1934 and all of its related rules.

PracticalESG

PracticalESG.com

Keeping you in-the-know on environmental, social and governance developments

Back in 2024, we wrote about litigation brought by the New York Attorney General against Brazilian beef producer JBS. The AG alleged that JBS’s climate goals were misleading in part because their “Net-Zero by 2040” goal was impossible given their current rate of emissions. That case has now settled, with JBS agreeing to pay $1.1 million. A recent Keller & Heckman memo discusses the settlement:

“On November 3, 2025, the New York Attorney General announced a $1.1 million settlement with the U.S. subsidiary of the world’s largest beef producer, ending the state’s lawsuit accusing the company of misleading the public about its environmental practices and sustainability commitments. The complaint, filed in February 2024 in New York state court, alleged that defendants JBS USA Food Company and JBS USA Food Company Holdings (together, JBS USA), and JBS USA’s parent, subsidiary, and affiliate companies, misled the public about a pledge to reduce greenhouse emissions and their stated goal to be ‘Net Zero by 2040.'”

JBS isn’t out of the woods yet. The memo notes that a group of environmental NGOs is challenging JBS on essentially the same claims as the New York Attorney General. Additionally, JBS has drawn scrutiny from NGOs over its agricultural practices, which the NGO’s allege contribute to global deforestation. This is another great example of how multiple claims may arise out of the same conduct, as different Plaintiffs may bring litigation across multiple jurisdictions. Once a case like New York’s is filed, other plaintiffs can use those filings as a foundation for their own greenwashing claims.

Our members can learn more about greenwashing here.

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The Editor

Zachary Barlow is a licensed attorney. He earned his JD from the University of Mississippi and has a bachelor’s in Public Policy Leadership. He practiced law at a mid-size firm and handled a wide variety of cases. During this time he assisted in overseeing compliance of a public entity and litigated contract disputes, gaining experience both in and outside of the courtroom. Zachary currently assists the PracticalESG.com editorial team by providing research and creating content on a spectrum of ESG… View Profile