have not hesitated to consider post-complaint developments as required in some circumstances, though some have expressed doubt that the time-of-filing rule uniformly governs subject matter jurisdiction in federal question cases. See, e.g., Iowa Tribe of Kan. & Neb. v. Salazar, 607 F.3d 1225, 1236-37 (10th Cir.2010) (finding no subject matter jurisdiction where the Interior Department, post-complaint, took certain land into trust for an Indian tribe’s benefit, an action for which Congress had expressly not waived sovereign immunity); ConnectU LLC v. Zuckerberg, 522 F.3d 82, 93 (1st Cir.2008) (declining to limit jurisdictional analysis to the initial complaint, where amended complaint set forth a proper jurisdictional basis); Nilssen v. Motorola, Inc., 203 F.3d 782, 784-85 (Fed.Cir.2000) (<HOLDING>); New Rock Asset Partners, L.P. v. Preferred
holding that the district court was not divested of subject matter jurisdiction upon the dismissal of the plaintiffs federal claims holding that district court correctly determined that it had been divested of jurisdiction to hear defendants counterclaims for invalidity and unenforceability when plaintiff had voluntarily dismissed its infringement claims without prejudice before trial holding that there was no federal subject matter jurisdiction under the private cause of action provision of the act holding that the circuit courts order concluding that it was without jurisdiction to entertain a complaint because the case had been dismissed without prejudice constituted a final order because all other claims either had been refiled or dismissed with prejudice holding subject matter jurisdiction divested because federal cause of action had been dismissed without prejudice