In Botter v. American Dental Ass'n, 124 S.W.3d 856, 861 (Tex. App.--Austin 2003, no pet.), the plaintiffs sued the American Dental Association ("ADA") for "marketing" a dangerous amalgam through its seal of approval in much the same way that MedCost here is accused of assisting in the procurement of an insurance program by approving its identification card for use in the MedCost network. 124 S.W.3d at 863. The Botters alleged that the ADA's endorsement and pamphlet advertising amalgam, its licensing of thousands of Texas dentist members who may not practice without such license, and its active governance of those members by an ethical code that would prevent them from warning about the amalgam constituted " purposeful actions in Texas that caused this litigation." Id. The Court held that specific jurisdiction did not exist because the Botters had not "sufficiently alleged that the ADA's extra-territorial conduct was focused on the plaintiff in Texas," and there were no purposeful contacts in Texas by the ADA. Id. at 864.