In Gulf Offshore Co v. Mobil Oil Corp, 453 U.S. 473; 101 S Ct 2870; 69 L. Ed. 2d 784 (1981), the United States Supreme Court clarified that the state courts have subject-matter jurisdiction over causes of action arising out of federal law unless federal law expressly confers exclusive jurisdiction to the federal courts. Gulf Offshore Co, supra at 477-479. "It is black letter law that the mere grant of jurisdiction to a federal court does not operate to oust a state court from concurrent jurisdiction over the cause of action." Id. at 479.