3-D Electric Co., v. Barnett Constr. Co
In 3-D Electric Co., v. Barnett Constr. Co., 706 S.W.2d 135, 137 (Tex. App.--Dallas 1986, writ ref'd n.r.e.), Texas had no jurisdiction over a Tennessee defendant who, as the general contractor to build a motel in Colorado, made an oral contract with a Texas corporation for electrical work.
The court held the defendant's contacts with Texas--an oral contract with a Texas corporation, payments to the Texas corporation, telephone calls, and correspondence to Texas--were not enough to establish minimum contacts. 3-D Electric, 706 S.W.2d at 142-43.