Courts have also suggested that nonresident, named plaintiffs might not need to establish personal jurisdiction, or at least that exercise of pendent personal jurisdiction may be appropriate, where jurisdiction is based on a federal question. See Allen v. Conagra Foods, Inc., No. 3:13-CV-01279-WHO, 2019 WL 5191009 at *2, n.4 (N.D. Cal. Oct. 15, 2019) ("Most courts that have declined to apply Bristol-Myers to class actions have done so in part because of the presence of a federal claim"); Sloan v. Gen. Motors LLC, 287 F. Supp. 3d 840, 859 (N.D. Cal. 2018) ("Therefore, where a federal court presides over litigation involving a federal question, the due process analysis does not incorporate the interstate sovereignty concerns that animated Bristol-Myers and which may be decisive in a state court's analysis."), on reconsideration, 438 F. Supp. 3d 1017, 1021 (N.D. Cal. 2020) (declining to exercise pendent jurisdiction because the case involved only diversity jurisdiction); Chavez v. Stellar Managment Grp. VII, LLC, No. 19-CV-01353-JCS, 2020 WL 4505482, at *8 (N.D. Cal. Aug. 5, 2020) (finding that Bristol-Myers does not apply to federal courts applying federal law and exercising pendent jurisdiction in a collective action under the Fair Labor Standards Act).