In Jenkins v. Bayview Loan Servicing, LLC, 2018 WL 5255318, at *3 (C.D.Cal., 2018), Judge Olguin remanded a Rosenthal Act claim due to the absence of federal jurisdiction.

Bayview contends that federal question jurisdiction exists because the Complaint refers to the FDCPA. (See Dkt. 1, NOR at 3). However, the Complaint asserts only state-law claims, including California’s Rosenthal Fair Debt Collection Practices Act, (“RFDPCA”), Cal. Civ. Code §§ 1788, et seq., (see Dkt. 1, Exh. 2, State-Court Complaint at ¶¶ 1-25), and the Complaint’s fleeting references to the FDCPA buried in a cause of action under the RFDCPA are insufficient to confer federal question jurisdiction. See Ghalehtak v. Fay Servicing, LLC, 2018 WL 2553570, *2 (N.D. Cal. 2018) (“Since the provisions are incorporated in and made part of state law, referencing the federal statute does not automatically transform [plaintiff’s] RFDCPA claim into a federal claim.”) (internal quotation marks omitted); Miller v. Yellow Pages, 2018 WL 2329716, *2 (S.D. Cal. 2018) (“Other district courts in the Ninth Circuit have concluded that a reference to the FDCPA in relation to a cause of action brought under the Rosenthal Act is insufficient to vest a district court with federal question jurisdiction.”) (internal quotation marks omitted).