In Thunderhead of Ankeny, Inc. v. Chicken Bones of Kearney, Inc., the US Court of Appeals for the Eighth Circuit affirmed the dismissal of a declaratory judgment action for lack of jurisdiction, holding that the only purpose of the relief sought was to vindicate defenses to pending state-law trade secrets, trademark, and trade dress claims and any federal-law controversy between the parties was too speculative to support jurisdiction under 28 U.S.C. § 1331.
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