Biovant LLC v. BTI AG LLC, 3:23-cv-01525

Plaintiff Biovant LLC d/b/a Biovante alleges conspiracy, fraud, unfair competition, and trade secret misappropriation against multiple defendants, including Chris Gorman, arising from a failed agricultural biotechnology partnership.
Biovante asserts eleven conspiracy claims and one claim for knowing participation in breach of fiduciary duty against Gorman.
Gorman moved to dismiss, claiming the court lacked personal jurisdiction over him as a non-resident defendant.
Biovante alleges Gorman had contacts with Texas: working for Biovante (operating in Texas), traveling to Texas, signing a Texas-governed NDA, and steering business to a new, Texas-based competitor.
The court considered whether Gorman’s contacts with Texas justified exercising specific personal jurisdiction for these claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Personal jurisdiction over Gorman	Gorman’s Texas contacts justify it	No sufficient contacts with Texas	Jurisdiction exists based on contacts
Claims arise from forum-related acts	Claims stem from Gorman’s Texas acts	Jurisdiction cannot rest on conspiracy ties	Claims arise from Gorman's Texas contacts
Fair play and substantial justice	No unfairness in Texas jurisdiction	Jurisdiction would offend due process	No due process violation
Claim-specific jurisdiction	All claims arise from same Texas acts	Jurisdiction must be claim-specific	All claims sufficiently related

Mullins v. TestAmerica, Inc., 564 F.3d 386 (5th Cir. 2009) (sets standard for personal jurisdiction under Texas long-arm statute)
Wilson v. Belin, 20 F.3d 644 (5th Cir. 1994) (addresses minimum contacts for general/specific jurisdiction)
McFadin v. Gerber, 587 F.3d 753 (5th Cir. 2009) (articulates three-step specific jurisdiction test)
Seiferth v. Helicopteros Atuneros, Inc., 472 F.3d 266 (5th Cir. 2006) (holds that specific jurisdiction is claim-specific)
Int’l Shoe Co. v. Washington, 326 U.S. 310 (U.S. 1945) (establishes due process standard for personal jurisdiction)