TMX Finance Holdings, Inc. v. Wellshire Financial Services, LLC D/B/A Loanstart Title Loans D/B/A Moneymax Title Loans and D/B/A Loanmax Meadowwood Financial Services, LLC D/B/A Loanstar Title Loans and D/B/A Moneymax Title Loans And Integrity Texas Funding, LP, 515 S.W.3d 1

Wellshire (three related Texas entities) sued several TMX-related entities and two individuals for misappropriation of trade secrets and tortious interference; most TMX co-defendants did not contest Texas jurisdiction.
TMX Finance, LLC (TMX-Finance) is an in-state subsidiary; TMX Finance Holdings, Inc. (TMX-Holdings) is an out-of-state parent holding company that allegedly has no employees, operations, or Texas contacts.
Wellshire alleged TMX-Holdings is the alter ego of TMX-Finance and sought to impute TMX-Finance’s Texas contacts to TMX-Holdings.
TMX-Holdings filed a special appearance asserting it has no Texas contacts; it submitted an affidavit from its VP (Christopher Wall) denying operational control over TMX-Finance.
The trial court denied the special appearance on alter-ego grounds; the court of appeals reversed and rendered dismissal of TMX-Holdings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Wellshire waived alter-ego theory by not pleading it in the original petition	Wellshire relied on its special-appearance response to allege alter-ego and submitted evidence; the court may consider those filings	TMX-Holdings contended Wellshire waived the theory by failing to plead it earlier	The court held no waiver: Rule 120a allows consideration of pleadings and special-appearance response when deciding jurisdiction
Whether Wellshire proved TMX-Holdings is the alter ego of TMX-Finance (sufficient to impute contacts)	TMX-Holdings (through common ownership, shared officers/headquarters, capital infusions, undocumented liabilities, and lack of formalities) exerts abnormal control over TMX-Finance and should be fused for jurisdictional purposes	TMX-Holdings showed no involvement in TMX-Finance’s operations, marketing, personnel, or policies; parental monitoring and ownership alone are insufficient to prove atypical control	The court held Wellshire failed to prove the requisite abnormal/atypical control; alter-ego not established; special appearance should have been granted

Kelly v. Gen. Interior Constr., Inc., 301 S.W.3d 653 (Tex. 2010) (standard and burden-shifting for special appearances)
BMC Software Belg., N.V. v. Marchand, 83 S.W.3d 789 (Tex. 2002) (implied findings and proof required to pierce corporate veil for jurisdiction)
PHC-Minden, L.P. v. Kimberly-Clark Corp., 235 S.W.3d 163 (Tex. 2007) (PHC‑Minden factors and requirement of a "plus" factor showing atypical control for alter-ego jurisdiction)
Moki Mac River Expeditions v. Drugg, 221 S.W.3d 569 (Tex. 2007) (long-arm statute reaches to the extent of due process)
Retamco Operating, Inc. v. Republic Drilling Co., 278 S.W.3d 333 (Tex. 2009) (purposeful availment minimum-contacts framework)
Spir Star AG v. Kimich, 310 S.W.3d 868 (Tex. 2010) (fair play and substantial justice factors in jurisdictional analysis)
Cappuccitti v. Gulf Indus. Prods., Inc., 222 S.W.3d 468 (Tex. App.—Houston [1st Dist.] 2007) (upholding alter-ego jurisdiction where individual and corporate control and intermingling were established)