GoSecure, Inc. v. CrowdStrike, Inc. and CrowdStrike Holdings, Inc.

Summary

The Business Court of Texas, Third Division, grants CrowdStrike, Inc.'s amended special appearance and dismisses all claims against it for lack of personal jurisdiction. The court concludes that CrowdStrike is not essentially at home in Texas for purposes of general jurisdiction because its principal place of business is in California and its Texas operations do not constitute an exceptional case. The court also holds that the plaintiff's trade-secret claims do not arise out of or relate sufficiently to CrowdStrike's Texas contacts.

Holdings

1. Texas lacks general personal jurisdiction over CrowdStrike because CrowdStrike is incorporated in Delaware, its principal place of business is in California under the nerve-center test, and its Texas operations are not so exceptional as to render it essentially at home in Texas.
2. Texas lacks specific personal jurisdiction over CrowdStrike because GoSecure's claims do not arise out of or relate to CrowdStrike's Texas contacts through a substantial connection to the operative facts of the litigation.
3. The court did not reach CrowdStrike's argument that exercising jurisdiction would offend traditional notions of fair play and substantial justice because Texas lacked personal jurisdiction on the minimum-contacts grounds.

Questions Presented

1. Whether Texas could exercise general personal jurisdiction over CrowdStrike because its Texas operations were substantial and continuous.
2. Whether CrowdStrike's Texas contacts were sufficiently connected to the operative facts of GoSecure's trade-secret misappropriation, conversion, and unjust-enrichment claims to support specific personal jurisdiction.
3. Whether the court needed to reach CrowdStrike's argument that exercising jurisdiction would violate traditional notions of fair play and substantial justice.

Disposition

dismissed