In Flanagan v. Royal Body Care, Inc. 232 S.W.3d 369 (Tex. App.--Dallas 2007, pet. denied), to support his claim that a substantial connection can exist even if the alleged injury did not occur in Texas.
It is true that the plaintiff's alleged use of and injury from the product in Flanagan did not occur in Texas. In that case, the claim at issue in the special appearance was not the plaintiffs' claim against the nonresident defendant; rather, the claim was one for contribution between the Texas seller of the product and the nonresident manufacturer. Id. at 377.
The Dallas Court of Appeals found a substantial connection between the contacts and the operative facts of the contribution claim because the nonresident defendant had marketed the product in Texas, sent the product to Texas, and personally met with the seller in Texas. Id.