In Nichols v. Canoga Industries (1978) 83 Cal.App.3d 956, the appellate court held that the decision of a federal court that it lacked jurisdiction over the subject matter did not have res judicata effect on the underlying action for breach of contract. The Nichols court explained (at p. 967): "A dismissal for lack of jurisdiction is not res judicata , and does not by the operation of collateral estoppel bar relitigation of substantive issues raised (4 Witkin, Cal. Procedure, supra, Judgment, 210, 211) except as to issues necessary for the determination of jurisdiction. ( Shore v. Shore (1954) 43 Cal.2d 677.)"