Copyright and Contracts: The Subject Matter Jurisdiction of Federal Courts under 28 U.S.C. 1338(A)

The subject matter jurisdiction of federal courts under the United States Copyright Act is said to present one of the "knottiest procedural problems in copyright jurisprudence." 2 That problem may be stated as follows: when does a copyright claim or issue under the Copyright Act which is factually related to a state law contract claim or issue constitute a "civil action arising under any Act of Congress relating to ... copyrights" sufficient to invoke exclusive federal court jurisdiction?3 This problem serves as the