OPINION
STAPLETON, District Judge:
Plaintiff Pennzoil Company ("Pennzoil") brought this action against the Department of Energy ("DOE") for a judicial determination of the validity of DOE Ruling 1975-15. (40 Fed.Reg. 40832, September 4, 1975). Jurisdiction is predicated on Section 211 of the Economic Stabilization Act of 1970, as amended, 12 U.S.C. § 1904 note at § 211, as incorporated in Section 502(a) of the Department of Energy Organization...
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