U.S. Energy Management, Inc. and Bradley R. Hitchcock v. JRB International, L.P., and Robert Brewer, 05-16-00505-CV

JRB sued U.S. Energy Management, Inc. (USEM) and Bradley Hitchcock for breach of contract and defamation; service efforts targeted Holly Hitchcock at USEM’s registered office (1116 Dobie Drive).
After motion for substituted service, USEM answered; later counsel withdrew and USEM became effectively unrepresented.
USEM moved its office to 1912 Red Rock Drive but did not update its registered agent/office with the Texas Secretary of State.
JRB mailed notice of summary-judgment submission and later the final judgment to the Dobie Drive address on file; some mail was returned as unclaimed/unable to forward.
The trial court granted default summary judgment in favor of JRB; USEM learned of the judgment only when receiver-related calls began and then filed a bill of review alleging lack of notice and asserting a meritorious defense (payment of commissions).
The trial court denied the bill of review; the court of appeals affirmed, holding USEM was negligent for failing to update its registered-office address and therefore could not claim lack of notice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether USEM was entitled to bill-of-review relief because it lacked proper notice of JRB’s summary-judgment submission and final judgment	USEM: JRB intentionally used an old address so USEM did not receive required notice; lack of notice excuses the bill-of-review elements and entitles relief	JRB: USEM had a statutory duty to maintain/update its registered agent/office; mailing to address on file was reasonably calculated to provide notice and USEM’s failure to update was negligent	Affirmed: USEM was negligent for failing to update its registered address; JRB’s service was reasonably calculated to provide notice; bill of review denied. Other appellate issues not reached.

Thompson v. Henderson, 45 S.W.3d 283 (Tex. App.—Dallas 2001) (elements and narrow scope of bill of review relief)
Caldwell v. Barnes, 154 S.W.3d 93 (Tex. 2004) (non-service relieves plaintiff of proving meritorious defense and causation element in bill of review)
Mabon Ltd. v. Afri-Carib Enter., Inc., 369 S.W.3d 809 (Tex. 2012) (extending non-service principles to include non-notice of trial setting)
Interaction, Inc. v. State, 17 S.W.3d 775 (Tex. App.—Austin 2000) (due-process notice requires means reasonably calculated to apprise defendant; courts indulge presumptions favoring final judgments)
Campus Invs., Inc. v. Cullever, 144 S.W.3d 464 (Tex. 2004) (failure to update registered office can support denial of bill of review for lack of notice)