Jurisdiction Over Non Resident Subsidiary Corporation In Texas

In Conner v. ContiCarriers & Terminals, Inc., 944 S.W.2d 405, 418 (Tex. App.--Houston [14th Dist.] 1997), it was undisputed that the two corporations maintained "significant ties," including the sharing of headquarters outside Texas; a unified payroll and benefits system; the Texas parent's provision of legal, accounting, and other services to the nonresident subsidiary; and the fact that 50 percent of the subsidiary's revenue came from servicing the parent corporation. 944 S.W.2d at 419. The plaintiffs argued both that: (1) the nonresident subsidiary had direct contacts with Texas and; (2) its Texas parent's actions could be imputed to the nonresident subsidiary under an alter ego theory. Id. Nonetheless, in discussing the subsidiary's direct contacts with Texas, neither the plaintiffs nor the court considered the nonresident subsidiary's everyday relations (unified benefits and payment systems, intercompany services, profit flow, etc.) with its Texas parent. See id. at 417. Rather, they considered these parent-subsidiary contacts only in connection with the alter ego analysis. See 944 S.W.2d at 418-19. Although the case was not decided on this point, we would expect that, if such routine parent-subsidiary contacts were important in determining the nonresident subsidiary's direct contacts with Texas, someone in Conner would have said so. No one did.