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Rules establishing exclusive jurisdiction of specific legal claims are designed to provide judges and litigants clear guidance in determining the forum in which a suit should be brought. A statutory grant of exclusive jurisdiction can minimize the cost of threshold litigation generated by the need to define the appropriate forum for adjudication. The modem development of the transactional case,' however, is not easily reconciled with exclusive jurisdiction; federal, state, and common law claims regularly merge to form the basis for litigation.2 The economies realized by the expansive concept of a case thus conflict with the efficient jurisdictional rule of exclusivity. The tensions between procedural reform3 and a jurisdictional pattern premised on the segregation of federal and state law claims are illustrated by the problems generated by the exclusive jurisdiction of the Securities Exchange Act of 1934.4 In particular, this tension is manifested by the disparate treatment of defenses and counterclaims arising under the Exchange Act. Although a state court may adjudicate an Exchange Act defense, it is not permitted to hear an Exchange Act counterclaim. This semi-exclusivity engenders a litigation pat-

The Securities Exchange Act and the Rule of Exclusive Federal Jurisdiction