claims. In that sense, proving the States’ claims does not necessarily depend on an interpretation of CRARA or any regulations enacted pursuant to CRARA. See, e.g., Bank of Am., 672 F.3d at 674-75 (rejecting removal of claims alleging violations of Nevada’s Deceptive Trade Practices Act even where they alleged that misrepresentations violated the federal Fair Debt Collection Practices Act); Glazer Capital Mgmt., LP v. Elec. Clearing House, Inc., 672 F.Supp.2d 371, 377 (S.D.N.Y.2009) (“That plaintiffs could have brought federal ... claims based on the factual allegations contained in the complaint is not sufficient to convert the state law claims [of fraud and negligent misrepresentation] into federal questions.”); Baker v. BDO Seidman, L.L.P., 390 F.Supp.2d 919, 925 (N.D.Cal.2005) (<HOLDING>). In arguing otherwise, S & P contends that, in
holding that the plaintiffs state law claims are preempted by federal law holding that in the context of federal immigration law the amount of loss to the victim of fraud or deceit does not refer to an element of the fraud or deceit but rather refers to the particular circumstances in which an offender committed fraud or deceit holding that plaintiffs claims of fraud and deceit and all the other cognate claims derived therefrom are capable of being resolved on state law bases without the interpretation of federal law holding state law fraud and deceit claims to be preempted holding that state law fraud claims are preempted by the federal labor law duty of fair representation