According to Shell, GreenHat asserts that the parties entered into thousands of separate and distinct agreements for the purchase of individual FTRs when they entered data reflecting FTR transfers to the FTR Center, i.e. GreenHat and Shell entered into new contracts by entering data into PJM`s FTR center to report bilateral transactions, separately and separately from the three written agreements of the parties. Shell`s petition argues that it has already fulfilled all of its obligations to GreenHat and that GreenHat`s claim in state court ultimately rests on Shell`s obligation to comply with the requirements of the PJM tariff.