The U.S. Court of Appeals for the Third Circuit provided more instruction regarding Federal Rule of Civil Procedure 19, which governs joinder, in a contractual dispute between two companies partnering to develop and operate natural gas projects.

After analyzing Rule 19, the court determined the district court had jurisdiction over absent joint operating agreement parties, and remanded the case for the lower court to reconsider whether to proceed in the absence of those who cannot be joined.

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