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The elements are the same but, you don't have to plead the COA's by elements insofar as most jurisdictions are notice pleading. Just make it bare bones.
Watch out for removal insofar as most astute counsel will attempt to remove it on pre-emption theories. I will assist you with remand if you need it. Jones-Day will do it automatically it you do not cap damages at 75k.
Fairly easy to beat though.
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