Does Defendant have jurisdiction to bring a claim for unfair business practices?

Defendants gave only cursory attention to the third claim for unfair business practices, arguing that because it is premised on the collective bargaining agreement it is federal in nature. In fact, this claim is based on a general pattern of allegedly unfair business practices beginning at an unknown date and spanning four years. The complaint does not say what those were,¹ but the four-year time frame, the generalized description, and the reference to "the practices alleged herein" (Compl., 47) suggest they include non-contractual unfair practices. They also include the state labor code violations. Because this claim could be established without reference to any federal law,² it is not a federal claim for jurisdictional purposes. See Rains v. Criterion Systems, Inc. , 80 F.3d 339, 346 (9th Cir. 1996).