Claims that defendants engaged in fraudulent or deceitful practices in connection with the sale of certain debentures, based entirely on state law, referred, in one paragraph, to violations of the Securities Act of 1933, the Securities Exchange Act of 1934, and the Investment Advisors Act of 1940. After the District Court questioned whether it had subject matter jurisdiction, the parties argued that the “mere mention” of the federal securities laws in a count of the complaint asserting a claim under state law was sufficient to establish federal question jurisdiction. Disagreeing with that position and holding, instead, that the “mere mention” of federal statutes in a state law count cannot convert it to a federal count or otherwise support subject matter jurisdiction, the Court dismissed the complaint for lack of subject matter jurisdiction. (Miller v. Cabell Financial Corp., 2007 WL 1725323 (N.D. Ohio June 13, 2007))