Goodman Manufacturing Company, L.P. v. Pacific Link, 4:18-cv-03499

Plaintiffs Goodman Manufacturing Co., L.P. and Goodman Co., L.P. (Houston, TX) allege defective disconnect pullouts manufactured by Wenzhou Qicheng Distribution Electrical Equipment Co., Ltd. (Qicheng), a Chinese company, and sold via U.S. distributor Pacific Link (Ohio).
Goodman conducted supplier diligence: Goodman employee Max Philo visited Qicheng in China (Qicheng paid his hotel and invoiced Goodman), prepared an assessment checklist, and communicated required improvements to Qicheng.
Goodman provided Qicheng detailed design drawings expressly referencing "The Goodman Family of Companies" and expected Qicheng to manufacture ~200,000 disconnect pullouts for delivery to Goodman in Texas via Pacific Link.
Goodman received and incorporated the pullouts into its air handlers, later alleging the parts were defective and prompting a nationwide recall.
Goodman sued Qicheng and Pacific Link for breach of contract, breach of warranty, negligence, and products liability; Qicheng moved to dismiss under Rule 12(b)(2) for lack of personal jurisdiction.
The magistrate judge recommended denying Qicheng's motion, concluding Qicheng had sufficient forum-directed contacts (stream-of-commerce with knowledge of Texas destination) and that exercising jurisdiction would be reasonable.

Issue	Plaintiff's Argument (Goodman)	Defendant's Argument (Qicheng)	Held
Whether Texas has specific personal jurisdiction over Qicheng via stream-of-commerce	Qicheng knowingly manufactured goods for Goodman in Houston and received detailed drawings; it expected delivery to Texas	Jurisdiction improper because Qicheng sold to a U.S. distributor (Pacific Link) and lacked contacts purposefully directed at Texas	Held: Yes. Qicheng had actual knowledge/expectation that the specific product would be delivered to Goodman in Texas, satisfying minimum contacts under stream-of-commerce
Whether the claims arise out of Qicheng’s forum contacts (nexus)	Claims (breach, negligence, products liability) directly stem from Qicheng’s manufacture/supply of the pullouts to Goodman in Texas	Qicheng implicitly argues lack of connection if jurisdiction is lacking	Held: Yes. Causes of action arise from Qicheng’s manufacture/delivery of the parts to Texas
Whether exercising jurisdiction would be fair and reasonable	Forum is appropriate because Goodman is headquartered in Texas and interests favor adjudication there	Litigating in Texas may burden a foreign defendant	Held: Held reasonable. Qicheng did not meet the heavy burden to show unreasonableness; traditional notions of fair play/substantial justice satisfied

Int'l Shoe Co. v. Washington, 326 U.S. 310 (1945) (establishes minimum contacts/due process framework)
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985) (purposeful availment and reasonableness inquiry)
Walden v. Fiore, 571 U.S. 277 (2014) (jurisdictional inquiry focuses on defendant's contacts with the forum)
Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915 (2011) (general jurisdiction standards)
Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408 (1984) (specific-jurisdiction principles)
Asahi Metal Ind. Co. v. Superior Court, 480 U.S. 102 (1987) (stream-of-commerce caution)
J. McIntyre Mach., Ltd. v. Nicastro, 564 U.S. 873 (2011) (plurality guidance on stream-of-commerce inquiries)
Luv N' Care, Ltd. v. Insta-Mix, Inc., 438 F.3d 465 (5th Cir. 2006) (prima facie burden on plaintiff at pre-discovery stage)
Ainsworth v. Moffett Eng'g, Ltd., 716 F.3d 174 (5th Cir. 2013) (Fifth Circuit's stream-of-commerce formulation)
Ruston Gas Turbines, Inc. v. Donaldson Co., Inc., 9 F.3d 415 (5th Cir. 1993) (knowledge that product would be delivered to a forum supports jurisdiction)
In re Chinese-Manufactured Drywall Prods. Liab. Litig., 753 F.3d 521 (5th Cir. 2014) (jurisdiction where defendant knew products were going to the forum)
Nuovo Pignone, SpA v. Storman Asia M/V, 310 F.3d 374 (5th Cir. 2002) (defendant's voluntary role in economic chain can show purposeful availment)