(“MISO”)-a Regional Transmission Organization operating a competitive wholesale market. However, in 2013, Entergy fully integrated its transmission facilities into the Midcontinent Independent System Operator, Inc. As the owner of a QF with no direct access to a competitive wholesale market, Occidental historically had the ability under PURPA to compel Entergy to purchase the output of Occidental’s QF at Entergy’s avoided cost, among other things. The underlying facts of the case center around Occidental Chemical Corporation (“Occidental”), the owner of a Qualifying Facility (“QF”) under PURPA in Entergy Louisiana, LLC’s (“Entergy”) service territory. While the Fifth Circuit found the doctrine applicable in the circumstances presented, it determined that the indefinite nature of the stay would unfairly harm the interests of one of the litigants. The district court had supported its indefinite stay by applying the doctrine of primary jurisdiction-a doctrine that permits a federal court with non-exclusive jurisdiction over a proceeding to, under appropriate circumstances, defer to another forum (such as an administrative agency like FERC) that also has non-exclusive jurisdiction over the issue, based on the court’s determination that the benefits of obtaining aid from the other forum outweigh the need for expeditious litigation. On January 4, 2016, the United States Court of Appeals for the Fifth Circuit (the “Fifth Circuit”) vacated a federal district court’s indefinite stay of proceedings before it involving disputed Public Utility Regulatory Policies Act (“PURPA”) issues while awaiting administrative action from FERC, and instead ordered a definite period of 180 days for FERC to act.