3. The question of how to value non-damages relief such as a declaratory judgment or injunction has divided the courts of appeal. See McInnis, The$75,000.01 Question: What is the Value of Injunctive Relief?, 6 Geo. Mason L. Rev. 1013 (1998). The majority rule is that the jurisdictional amount is tested by the value to the plaintiff of the relief sought, but some courts have held that the larger of two figures, either worth of the relief to the plaintiff or its cost to the defendant, should control. See Pinahs, Diversity Jurisdiction and Injunctive Relief: Using a “Moving-Party Approach” to Value the Amount in Controversy, 95 Minn. L.

Rev. 1930 (2011).