Jason R. Searcy, as Trustee of the Exempt Assets Trust v. Parex Resources, Inc., 496 S.W.3d 58

Nabors (Bermudian) owned all Class A shares of Ramshorn (Bermudian), which operated oil and gas assets in Colombia; Nabors had key executives and management functions based in Houston, Texas.
ERG (Texas) negotiated and signed an SPA with Nabors Global for Ramshorn shares; closing failed and ERG sued in Texas for specific performance and tortious interference.
Parex Canada (Canadian) pursued the same shares through advisors at Royal Bank of Canada; Parex Canada’s subsidiary Parex Colombia (and later Parex Bermuda) negotiated and accessed diligence on a Houston-hosted virtual data room and exchanged numerous communications with Nabors’ Houston staff.
ERG sued Parex Canada, Parex Bermuda, and Ramshorn in Texas for tortious interference and fraud; the nonresidents filed special appearances contesting personal jurisdiction.
The trial court found jurisdiction over Parex Canada and Ramshorn but not Parex Bermuda; the court of appeals reversed as to Parex Canada; the Texas Supreme Court affirmed that Texas lacks jurisdiction over Parex Canada and Parex Bermuda but has specific (not general) jurisdiction over Ramshorn.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Texas has general jurisdiction over Parex Canada	Parex Canada’s repeated contacts with Texas (emails/calls/data-room access) make it essentially at home	Parex Canada has no offices, property, employees, bank accounts, or continuous operations in Texas	No general jurisdiction over Parex Canada
Whether Texas has specific jurisdiction over Parex Canada for tortious interference	Parex Canada purposefully directed numerous communications and bids into Texas and thus foreseeably interfered with ERG’s Texas contract	Parex Canada’s contacts were fortuitous/attenuated — it sought Colombian assets, not to transact or profit in Texas; communications were incidental	No specific jurisdiction over Parex Canada
Whether Texas has specific jurisdiction over Ramshorn (Bermudian) for fraud claims	ERG: Ramshorn (through Nabors executives) made misrepresentations in Texas	Ramshorn: limited Texas ties and deals were offshore; lack of sufficient contacts	Yes — specific jurisdiction over Ramshorn: Nabors executive (Jordan Smith) acted with actual/apparent authority and negotiated/sought sale in Texas
Whether Texas has jurisdiction over Parex Bermuda (the purchaser subsidiary)	ERG: Parex Bermuda ratified Parex Canada’s contacts and accepted benefits, so jurisdiction follows	Parex Bermuda: no independent Texas contacts; any ratification did not adopt the earlier allegedly tortious acts	No jurisdiction over Parex Bermuda

Int’l Shoe Co. v. Washington, 326 U.S. 310 (establishes minimum‑contacts due process framework)
Calder v. Jones, 465 U.S. 783 (specific jurisdiction where defendants expressly aimed tortious conduct at forum)
Keeton v. Hustler Magazine, Inc., 465 U.S. 770 (forum where defendant exploited market supports jurisdiction)
Walden v. Fiore, 134 S. Ct. 1115 (2014) (defendant‑focused minimum‑contacts; plaintiff’s forum connections cannot be attributed to defendant)
Daimler AG v. Bauman, 134 S. Ct. 746 (2014) (general jurisdiction requires affiliations so continuous and systematic as to render defendant essentially at home)
Goodyear Dunlop Tires Ops., S.A. v. Brown, 131 S. Ct. 2846 (2011) (limits on general jurisdiction over foreign subsidiaries)
Michiana Easy Livin’ Country, Inc. v. Holten, 168 S.W.3d 777 (Tex. 2005) (specific jurisdiction requires defendant contacts, not plaintiff’s unilateral acts)
Moncrief Oil Int’l Inc. v. OAO Gazprom, 414 S.W.3d 142 (Tex. 2013) (contacts that are the crux of the tort support specific jurisdiction)
Moki Mac River Expeditions v. Drugg, 221 S.W.3d 569 (Tex. 2007) (substantial‑connection requirement for relatedness in specific jurisdiction)