The absence of “natural persons” in the NGA’s anti-manipulation provision is particularly significant because when the NGA wishes to reference natural persons, it makes such reference clear. See, e.g., 15 U.S.C. § 717a-(1) (defining the term “person” as including both “an individual or a corporation”). The NGA has several provisions that are applicable to both natural persons and juridical persons.

While the term “entity” is not defined in the NGA, the term “person” is defined as “an individual or a corporation.” 15 U.S.C. § 717a(1). In Wolverine, the term “licensee” was not defined, but the term “person” was also defined to include an individual or corporation.

3 Columbia is a wholly owned subsidiary of the Columbia Energy Group, which, in turn, is a wholly owned subsidiary of NiSource, Inc. 4 15 U.S.C. § 717a(6) (2012). Case 3:16-cv-00268-KRG Document 18-1 Filed 03/14/17 Page 2 of 12 Docket No.

35 Because “entity” is not defined in EPAct or the NGA, the term should be construed in accordance with its ordinary meaning.36 In general, the term “entity” may include “a natural person, a corporation, a partnership, a limited liability company, a limited partnership, a trust, an estate, an association.”37 Moreover, Congress’ decision to modify “entity” with “any” prohibits 34 15 U.S.C. § 717a(1) (emphasis added). The NGA’s definition of “person,” which includes corporations, is consistent with the broad legal meaning of “person.”

The NGA has several provisions that are applicable to both human beings and companies (see, e.g., 15 U.S.C. § 717g-(a) (imposing burden of proof on any “person” making, authorizing, or requiring certain accounting entries questioned by FERC); 15 U.S.C. § 717m-(d) (permitting judicial compulsion of testimony and document production in cases of contumacy by any “person”)); various provisions of the NGA are not aimed at “entities” but rather at “persons” (see, e.g., 15 U.S.C. § 717b (providing that no “person” shall import or export natural gas without FERC’s express permission)); and the NGA explicitly defines the term “person” as including both “an individual or a corporation.” 15 U.S.C. § 717a-(1). The NGA uses the term “persons” (meant to include both human beings and companies) in various places to describe provisions applicable to both natural persons and organizations, but notably does not use such term when describing the anti-manipulation provision and the market transparency rules.