Moncrief Oil International, Inc. v. Gazprom, 332 S.W.3d 1

Moncrief Oil International, Inc. appeals an interlocutory order granting special appearances by Gazprom entities in a Texas suit.
The Court of Appeals evaluates general and specific jurisdiction over Gazprom, Gazprom Export, and Gazprom Marketing & Trading, Ltd., and addresses related discovery issues.
Moncrief alleges misappropriation of trade secrets and tortious interference with a Texas-based Occidental joint venture, plus conspiracy theories.
Gazprom argues lack of general jurisdiction and lack of specific jurisdiction related to the Texas claims, plus disputes over GMT USA and GMT ownership.
The court discusses a detailed timeline of Gazprom’s contacts with Texas, including meetings in Texas and numerous communications with Moncrief in and outside Texas.
The trial court’s ruling on the special appearances is affirmed, with direction on how the issues relate to jurisdictional analysis.

Issue	Plaintiff's Argument	Defendant's Argument	Held
General jurisdiction over Gazprom in Texas	Moncrief asserts Gazprom had continuous and systematic Texas contacts.	Gazprom contends its Texas contacts were insufficient for general jurisdiction.	No general jurisdiction over Gazprom in Texas.
Specific jurisdiction for tortious interference with the Occidental joint venture	Gazprom interfered with a Texas-based venture and damages occurred in Texas.	Interference occurred in California; no Texas-related nexus.	No specific jurisdiction for this tort claim.
Specific jurisdiction for misappropriation of trade secrets	Disclosures and use of trade secrets occurred in Texas; jurisdiction attaches.	Alleged disclosures could have occurred elsewhere; not purposeful in Texas.	Texas long-arm jurisdiction exists and is grounded in due process for this claim.
Alter ego/ fusion between Gazprom Marketing & Trading, Ltd. and GMT USA for jurisdiction	GMT USA is an alter ego; GMT USA’s Texas contacts should be imputed to Gazprom Marketing & Trading, Ltd.	No proven corporate fusion; separate entities with independent books.	No jurisdictional imputation; GMT USA not imputed to Gazprom Marketing & Trading, Ltd.
Depositions of Medvedev and Ivanov (jurisdictional discovery)	Depositions could yield material jurisdictional facts.	Discovery denied; depositions would be cumulative and non-material.	No abuse of discretion; depositions properly denied.

Michiana Easy Livin' Country, Inc. v. Holten, 168 S.W.3d 777 (Tex. 2005) (minimum contacts focus on defendant's activities and expectations; phone calls alone insufficient for due process)
Moki Mac River Expeditions v. Drugg, 221 S.W.3d 569 (Tex. 2007) (defining general vs. specific jurisdiction; nexus between defendant, forum, and litigation)
PHC-Minden L.P. v. Kimberly-Clark Corp., 235 S.W.3d 163 (Tex. 2007) (broad long-arm statute; due process limitations on asserted jurisdiction)
BMC Software Belg., N.V. v. Marchand, 83 S.W.3d 789 (Tex. 2002) (implied findings in nonevidentiary hearings; standard of review on jurisdiction)
Retamco Operating, Inc. v. Republic Drilling Co., 278 S.W.3d 333 (Tex. 2009) (analysis of where torts and injuries occur for jurisdictional purposes)
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985) (purposeful availment; minimum contacts require more than contracts with out-of-state party)
Glencoe Capital Partners II, LP v. Gernsbacher, 269 S.W.3d 157 (Tex.App.-Fort Worth 2008) (purposeful availment based on multiple contacts beyond phone calls)
Citrin Holdings, LLC v. Minnis, 305 S.W.3d 269 (Tex.App.-Houston 2009) (telephonic participation in board-related activities as contacts)
Fish v. Tandy Corp., 948 S.W.2d 886 (Tex.App.-Fort Worth 1997) (contracts and negotiations with Texas-based entities as jurisdictional basis)
Cent. Freight Lines Inc. v. APA Transp. Corp., 322 F.3d 376 (5th Cir. 2003) (factor for analysis of jurisdiction in circuit court)