The Federal Maritime Commission (FMC) is reviewing whether the World Shipping Council (WSC) has standing to fall under the jurisdiction of the FMC and, therefore, enjoy anti-trust immunity. The crux of the issue is, while members of the WSC are ocean carriers, the WSC is a trade association. And, “a trade association not involved in providing ocean transportation service does not appear to be engaged in the type of conduct Congress intended to immunize from scrutiny by antitrust enforcers and private plaintiffs.”