American Refrigeration Company, Inc. v. Tranter, Inc., 02-15-00265-CV

ARC, a Massachusetts corporation, contracted to install an ice-rink refrigeration system at Dartmouth College; REC (a Massachusetts designer) specified a Tranter heat exchanger.
A Tranter heat exchanger was manufactured in Wichita County, Texas, shipped to RVS in Bryan, Texas, and then forwarded to New Hampshire; the system was installed in August 2011.
The system failed in June 2012; Dartmouth alleged the exchanger was defective and demanded over $880,000 from Tranter, ARC, and RVS.
Tranter sued ARC, RVS, and Dartmouth in Wichita County, Texas, seeking declaratory relief that Tranter was not liable and that no warranties existed; ARC filed a special appearance denying Texas personal jurisdiction.
Evidence included ARC president Sirois’s affidavit denying Texas contacts and RVS president Jordan’s affidavit plus an order-acknowledgement and a record of 63 orders ARC allegedly placed with RVS from 2004–2015.
The trial court denied ARC’s special appearance; the court of appeals reversed, holding Texas lacked personal jurisdiction over ARC and dismissed Tranter’s claims against ARC.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Texas has specific jurisdiction over ARC	Tranter: ARC contracted with RVS in Texas to purchase the heat exchanger, and performance in Texas ties the claim to Texas	ARC: ARC is Massachusetts-based, had no Texas operations or contacts with Tranter, and did not purposefully avail itself of Texas	No specific jurisdiction—ARC’s contacts (purchasing goods shipped F.O.B. Texas; payments) insufficient for minimum contacts
Whether Texas has general jurisdiction over ARC	Tranter: ARC’s repeated purchases (63 orders totaling ~$890,000) from RVS show continuous and systematic contacts	ARC: Regular vendor purchases alone do not establish continuous and systematic forum contacts; ARC lacks other Texas presence	No general jurisdiction—purchases from a Texas vendor do not alone support general jurisdiction

Moki Mac River Expeditions v. Drugg, 221 S.W.3d 569 (Tex. 2007) (describes plaintiff’s pleading burden and purposeful-availment framework)
BMC Software Belg., N.V. v. Marchand, 83 S.W.3d 789 (Tex. 2002) (trial-court fact findings and standard for special-appearance review)
Michiana Easy Livin’ Country, Inc. v. Holten, 168 S.W.3d 777 (Tex. 2005) (nonresident status can satisfy defendant’s initial burden absent specific forum-directed acts)
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985) (contract alone insufficient for jurisdiction without purposeful availment)
Helicopteros Nacionales de Colombia v. Hall, 466 U.S. 408 (1984) (mere purchases from forum do not establish general jurisdiction)
International Shoe Co. v. Washington, 326 U.S. 310 (1945) (minimum contacts and fair play due-process standard)