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federal question, Louisville v. Mottley: Fed issue must be in well pled complaint (exclusion) yes American Well: (Harmes) Does c/a arise under federal law? (inclusion), Louisville v. Mottley: Fed issue must be in well pled complaint (exclusion) no No FQ jurisdiction, Smith:(Merrel) is federal issue outcome determinative? (exclusion) yes Merrel: interp Smith is FQ O/D & is FQ really important, American Well: (Harmes) Does c/a arise under federal law? (inclusion) no Smith:(Merrel) is federal issue outcome determinative? (exclusion), American Well: (Harmes) Does c/a arise under federal law? (inclusion) yes Have FQ jurisdiction