The response brief filed by plaintiff Solenex LLC repeatedly asks this Court to disregard controlling precedent; ignore plain statutory, regulatory, and contractual language; and adopt outlier positions. Solenex suggests that such extreme actions are necessary in this case to avoid
injustice due to the cancellation of its federal mineral lease in the Hall Creek area of the Badger-Two Medicine region, but dismisses the injustice that would befall the public interest if Solenex’s position were to prevail. The Court should reject Solenex’s arguments.