On the other hand, federal JX can exist when the state law claims are completely preempted by federal law. That’s a rare thing, but it IS a thing.

And in fairness to ROR, I actually used this same argument in a different context – when the actor Colin Farrell sued a client of mine for attempting to distribute a sex tape showing him and a Playboy bunny. The Complaint only asserted state law claims, but I nevertheless removed it to federal court on the basis that the CA state law claims were all completely preempted by federal law (the Copyright Act).

I personally think this was a good argument which should have worked, but the federal court disagreed and remanded the case without awarding fees. See: https://storage.courtlistener.com/recap/gov.uscourts.cacd.178751/gov.uscourts.cacd.178751.21.0.pdf

Still, in my view, arguing complete preemption of a state law claim under Section 230 is a bad way of trying to get yourself into federal court. It’s just way too easy to shoot this down with the well-settled rule that a federal defense, by itself, is never enough to create federal question jurisdiction.