Undertakings or agreements which are merely personal in their character, or which are preliminary or leading to maritime contracts are not recognized as within the admiralty jurisdiction.[i]  Moreover, under the preliminary contract doctrine, if a contract is deemed to be preliminary to a maritime contract, then the services performed under that contract cannot be said to be “maritime in nature.”  A preliminary contract could not pass the nature and subject matter test, and admiralty jurisdiction would be denied.[ii]

[i] The Harvey & Henry, 86 F. 656 (2d Cir. N.Y. 1898)

[ii] Pacific Growth S.A. v. Aon Corp., 1999 U.S. Dist. LEXIS 15381 (S.D.N.Y. 1999)