Energy arbitragers, who profit from price fluctuations in the electricity market, wanted to get paid out of a fund of surplus fees collected by a Regional Transmission Organization. The fund was established under Federal Energy Regulatory Commission ("FERC") authority to cover costs incurred by energy companies in transmitting electricity to end users. FERC denied the traders' request for a share of the fund. The Court held that FERC reasonably approved surplus allocation as a way to prevent market manipulation by traders who never actually transmit or receive electricity. Black Oak Energy, LLC v. FERC.