Supreme Court of Texas 

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No. 21-0994 

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LG Chem America, Inc. and LG Chem, Ltd., 

Petitioners, 

v. 

Tommy Morgan, 

Respondent

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On Petition for Review from the 

Court of Appeals for the First District of Texas 

═══════════════════════════════════════

Argued March 22, 2023 

JUSTICE HUDDLE delivered the opinion of the Court. 

Justice Young did not participate in the decision. 

This is a products-liability case in which two nonresident 

defendants contest personal jurisdiction. The plaintiff bought a 

lithium-ion battery at a store in Texas and was injured when he used it 

to charge his e-cigarette. The defendants do not dispute they sold and 

distributed the same batteries to Texas manufacturers. Yet they urge 

personal jurisdiction is lacking because they did not send the batteries 

to Texas for resale to individual consumers to use with e-cigarettes; 
2 

rather, they only expected that the manufacturers would incorporate the 

batteries into branded consumer products, such as cordless power tools 

and laptop computers. They argue the plaintiff’s claims arise out of the 

use of the battery in a way they never intended by an individual 

consumer they never targeted and thus are insufficiently related to the 

defendants’ Texas contacts to justify haling them into a Texas court. 

We hold, consistent with our precedents, that the 

minimum-contacts analysis requires evaluation of a defendant’s 

contacts with the forum—Texas—as a whole. Where, as here, a 

defendant purposefully avails itself of the privilege of doing business in 

Texas by selling and distributing into Texas the very product that 

injures a plaintiff, personal jurisdiction is not lacking merely because 

the plaintiff is outside a segment of the market the defendant targeted. 

Put differently, the relatedness prong of the minimum-contacts analysis 

does not require that the plaintiff’s claims arise out of a set of facts 

mirroring the defendant’s expectations about the course its product 

would follow after it entered Texas. The trial court and the court of 

appeals correctly concluded the exercise of personal jurisdiction over the 

defendants is, on this record, consistent with due process. We therefore 

affirm the court of appeals’ judgment. 

I. Background 

Tommy Morgan, a Texas resident, was injured when a lithium-ion 

battery “exploded” in his pocket. Morgan purchased the battery—
3 

referred to by its model number, 186501—from Vapor Sense, a store in 

Texas, to charge an e-cigarette he bought at the same store. The model 

18650 battery that injured Morgan was allegedly manufactured by LG 

Chem, Ltd., a company headquartered in South Korea. Morgan brought 

products-liability claims2 against LG Chem and its American 

distributor, LG Chem America, Inc., as well as the manufacturer of the 

e-cigarette and Vapor Sense. 

Morgan’s original petition included the following jurisdictional 

allegations: 

 LG Chem “is in the business of . . . selling, exporting, 

importing, distributing and/or otherwise introducing 

lithium-ion batteries into the stream of commerce” and “was 

conducting business in the State of Texas in a continuous and 

systematic manner by marketing and/or selling its 

manufactured products in the State of Texas.” 

 LG Chem America “works in conjunction with [LG Chem] in 

the business of . . . selling, exporting, importing, distributing 

and/or otherwise introducing lithium-ion batteries into the 

stream of commerce” and “was and continues to conduct 

business in the State of Texas in a continuous and systematic 

manner by marketing and/or selling its manufactured 

products in the State of Texas.” 

 “[T]he lithium-ion battery that injured [Morgan] was 

manufactured, marketed, sold, distributed, or otherwise 

1 The battery’s model number refers to its dimensions—it is 18 mm in 

diameter, 65 mm in length, and cylindrical in shape. See Yamashita v. LG 

Chem, Ltd., 62 F.4th 496, 501 (9th Cir. 2023). 

2 Morgan asserts the following causes of action: (1) negligence, (2) strict 

liability for manufacturing defects, (3) strict liability for marketing defects, 

(4) breach of express warranty, (5) breach of implied warranty, (6) violations of 

the Deceptive Trade Practices–Consumer Protection Act, and (7) gross 

negligence. 
4 

placed into the stream of commerce by [LG Chem America] 

and/or [LG Chem].” 

 “At all relevant times, Defendants were engaged in the 

business of . . . selling and/or otherwise intentionally placing 

. . . batteries into the stream of commerce and directing such 

products to Texas, including the . . . battery that injured 

[Morgan].” 

LG Chem and LG Chem America each filed a special appearance, 

challenging the court’s personal jurisdiction over them. Each supported 

its special appearance with an employee’s affidavit. The affidavits 

averred that neither LG Chem defendant is incorporated or 

headquartered in Texas. Neither affidavit denied that LG Chem or LG 

Chem America directed the sale and distribution of its products, 

including lithium-ion batteries, to Texas. Instead, the affidavits denied 

the LG Chem defendants sold or distributed their batteries for use by 

individual consumers or for e-cigarettes. For example, LG Chem’s 

senior manager, Joon Young Shin, averred that LG Chem “does not 

distribute, advertise, or sell 18650 cells directly to consumers, and has 

never authorized any manufacturer, wholesaler, distributor, retailer, or 

re-seller to distribute, advertise, or sell [LG Chem]’s lithium-ion power 

cells directly to consumers as standalone batteries” (emphases added). 

Similarly, LG Chem America’s compliance manager, HyunSoo Kim, 

averred that LG Chem America “has never sold or distributed any power 

cells meant for e-cigarettes or vaping devices” and “has never authorized 

any manufacturer, wholesaler, distributor, retailer, or re-seller . . . to 

advertise, distribute, or sell LG brand power cells in Texas, or anywhere 

else, for use by individual consumers as power cells in e-cigarette or 

vaping devices” (emphases added). 
5 

Morgan responded to both special appearances and conceded that 

neither LG Chem defendant is at home in Texas for purposes of general 

personal jurisdiction. But Morgan insisted that both are subject to 

specific personal jurisdiction. In particular, Morgan asserted that LG 

Chem “directly targets the Texas market [by] shipping lithium-ion 

batteries, like the battery at issue here, directly into the State of Texas.” 

In support, Morgan submitted a declaration from his attorney with 

several attachments. The bulk of the attachments consists of over 2,000 

pages of spreadsheets, purportedly reflecting U.S. Customs data from 

November 2006 through May 2019, showing LG Chem’s shipments of 

thousands of products to Texas companies or through Texas ports. 

Some, but not all, of these entries seemingly show that LG Chem 

shipped lithium-ion batteries (and specifically model 18650 batteries) to 

Texas. Many of those shipments were consigned to LG Chem America, 

a subsidiary that generates about one-fifteenth of its total revenue in 

Texas and is responsible for “sales and trading” of LG Chem’s products. 

In reply, the LG Chem defendants argued they are not subject to 

specific personal jurisdiction because Morgan has not shown that his 

claims arise from or are related to any purposeful contacts between the 

LG Chem defendants and Texas. Neither defendant objected to the 

spreadsheets or other evidence attached to Morgan’s responses. 

Following a hearing at which no additional evidence was offered, the 

trial court denied both special appearances. 

Both LG Chem defendants filed an interlocutory appeal. See TEX.

CIV. PRAC. & REM. CODE § 51.014(a)(7) (allowing an appeal from an order 

granting or denying a defendant’s special appearance). The court of 
6 

appeals affirmed, concluding that each of Morgan’s products-liability 

claims for the LG Chem battery that allegedly injured him in Texas 

“arises from or relates to [LG Chem]’s conduct in designing and 

marketing its batteries for the Texas market, and marketing, selling, 

and distributing them to customers here.” 663 S.W.3d 217, 237 (Tex. 

App.—Houston [1st Dist.] 2020). With respect to LG Chem America, the 

court likewise concluded that Morgan’s claims “arise out of the [LG 

Chem] batteries that [LG Chem America] marketed, sold, and 

distributed to customers in Texas, including Morgan.” Id. at 238. The 

court of appeals reasoned that both LG Chem defendants could 

reasonably anticipate being haled into a Texas court when an allegedly 

defective and unreasonably dangerous LG Chem battery that they sold 

in Texas causes an injury in Texas. Id. at 237, 238–39. The LG Chem 

defendants filed petitions for review,3 which we granted. 

II. Applicable Law 

A court must have personal jurisdiction over a defendant to issue 

a binding judgment. Luciano v. SprayFoamPolymers.com, LLC, 

625 S.W.3d 1, 7–8 (Tex. 2021). Texas courts may exercise personal 

jurisdiction over a nonresident defendant if it is (1) authorized by the 

Texas long-arm statute, TEX. CIV. PRAC. & REM. CODE §§ 17.041–.045; 

and (2) consistent with federal due-process guarantees. Luciano, 

625 S.W.3d at 8. The long-arm statute permits courts to exercise 

jurisdiction over a defendant who “does business in this state,” which 

3 LG Chem and LG Chem America filed separate petitions for review, 

but they jointly filed a brief on the merits. Nowhere in this Court do the LG 

Chem defendants suggest that the jurisdictional analysis for LG Chem is 

different than that for LG Chem America. 
7 

the Legislature defines to include, among other things, a nonresident 

defendant who “commits a tort in whole or in part in this state.” TEX.

CIV. PRAC. & REM. CODE § 17.042(2). 

A nonresident defendant may challenge a Texas court’s personal 

jurisdiction over it by filing a special appearance. TEX. R. CIV. P. 120a. 

The plaintiff bears the initial burden to plead sufficient allegations to 

bring the nonresident defendant within the reach of the long-arm 

statute. Kelly v. Gen. Interior Constr., Inc., 301 S.W.3d 653, 658 (Tex. 

2010). The defendant then bears the burden to negate all bases of 

personal jurisdiction alleged by the plaintiff. Id. The defendant can 

negate personal jurisdiction on either a factual or legal basis. Id. at 659. 

It can present evidence that contradicts the plaintiff’s factual allegations 

supporting the assertion of personal jurisdiction, and the plaintiff can 

then respond with its own evidence supporting its allegations. Id. Or 

the defendant can show that even if the plaintiff’s alleged facts are true, 

the evidence is legally insufficient to establish personal jurisdiction. Id. 

Whether a court has personal jurisdiction over a party is a question of 

law that we review de novo, although the court may have to resolve 

questions of fact. Luciano, 625 S.W.3d at 8. 

A state court’s exercise of personal jurisdiction over a nonresident 

defendant is constrained by the constitutional right to due process. See

U.S. CONST. amend. XIV, § 1. A tribunal’s authority depends on the 

defendant’s having sufficient “minimum contacts” with the forum state 

such that the maintenance of the suit is reasonable and “does not offend 

‘traditional notions of fair play and substantial justice.’” Int’l Shoe Co. 

v. Washington, 326 U.S. 310, 316–17 (1945) (quoting Milliken v. Meyer, 
8 

311 U.S. 457, 463 (1940)). “In giving content to that formulation, the 

Court has long focused on the nature and extent of ‘the defendant’s 

relationship to the forum State.’” Ford Motor Co. v. Mont. Eighth Jud. 

Dist. Ct., 141 S. Ct. 1017, 1024 (2021) (quoting Bristol-Myers Squibb Co. 

v. Superior Ct., 582 U.S. 255, 262 (2017)). 

“[T]o the extent that a corporation exercises the privilege of 

conducting activities within a state, it enjoys the benefits and protection 

of the laws of that state.” Int’l Shoe, 326 U.S. at 319; see also Hanson v. 

Denckla, 357 U.S. 235, 253 (1958) (“[I]t is essential in each case that 

there be some act by which the defendant purposefully avails itself of 

the privilege of conducting activities within the forum State, thus 

invoking the benefits and protections of its laws.”). These benefits and 

protections include “the enforcement of contracts, the defense of 

property, [and] the resulting formation of effective markets.” Ford, 

141 S. Ct. at 1029. But the state’s assistance creates reciprocal 

obligations, including an obligation that products the defendant sells or 

distributes in the state be safe for its citizens to use. Id. at 1030. A 

state’s enforcement of that commitment through the exercise of personal 

jurisdiction can “hardly be said to be undue.” Id. (quoting Int’l Shoe, 

326 U.S. at 319). 

There are two kinds of personal jurisdiction: “general (sometimes 

called all-purpose) jurisdiction and specific (sometimes called 

case-linked) jurisdiction.” Id. at 1024. Morgan concedes that he cannot 

establish general jurisdiction. Therefore, the only issue in this case is 

whether Morgan has established specific personal jurisdiction over the 

LG Chem defendants. 
9 

As noted, to establish specific personal jurisdiction over a 

nonresident defendant, a plaintiff must demonstrate that the defendant 

has minimum contacts with the forum state such that maintenance of 

the suit does not offend traditional notions of fair play and substantial 

justice. Luciano, 625 S.W.3d at 8. This specific-jurisdiction analysis 

involves “two co-equal components”: purposeful availment and 

relatedness. Moki Mac River Expeditions v. Drugg, 221 S.W.3d 569, 579 

(Tex. 2007). 

First, the defendant must have purposefully availed itself of the 

privilege of conducting activities in the forum state. Luciano, 

625 S.W.3d at 8. In cases involving products liability, this Court has 

adopted the “stream-of-commerce-plus” standard to establish whether 

this purposeful availment exists. See id. at 13; Moki Mac, 221 S.W.3d 

at 577 (citing Asahi Metal Indus. Co. v. Superior Ct., 480 U.S. 102, 112 

(1987) (plurality op.)). Under that standard, the defendant’s act of 

placing a product into the stream of commerce does not establish 

purposeful availment unless there is “additional conduct” evincing “an 

intent or purpose to serve the market in the forum State.” Moki Mac, 

221 S.W.3d at 577 (quoting Asahi, 480 U.S. at 112). Mere knowledge 

that the defendant’s product will reach the forum state is not sufficient. 

Luciano, 625 S.W.3d at 13 (citing CMMC v. Salinas, 929 S.W.2d 435, 

439 (Tex. 1996)). 

Second, the plaintiff’s claim must arise out of or relate to the 

defendant’s contacts with the forum. Id. at 9. “This so-called 

relatedness inquiry defines the appropriate ‘nexus between the 

nonresident defendant, the litigation, and the forum.’” Id. at 14 (quoting 
10 

Moki Mac, 221 S.W.3d at 579). Under our precedents, the plaintiff must 

demonstrate a “substantial connection” between the defendant’s 

contacts and the operative facts of the litigation. Moki Mac, 221 S.W.3d 

at 585. 

The U.S. Supreme Court recently examined the relatedness 

inquiry and explained that, while a plaintiff need not establish a strict 

causal relationship between the defendant’s contacts and the plaintiff’s 

claim, neither is it the case that anything goes. Ford, 141 S. Ct. at 1026. 

Ford concerned two lawsuits in which plaintiffs brought 

products-liability claims against a nonresident car manufacturer after 

its cars were involved in accidents in the plaintiffs’ home states. There 

was no dispute that Ford purposefully availed itself of the two states’ 

markets, including by advertising and selling its cars (including the two 

models at issue in the lawsuits) in those states. Id. at 1028. But in each 

case, Ford argued that personal jurisdiction was lacking because it did 

not sell, design, or manufacture the particular injury-causing car in that 

state. So, Ford’s argument went, its contacts with the forum did not give 

rise to the plaintiff’s claim. See id. at 1026. The Court disagreed with 

Ford, held there was personal jurisdiction, and reaffirmed that specific 

personal jurisdiction requires a “connection” between a plaintiff’s suit 

and the defendant’s activities. Id. It concluded a “causal showing” is 

not required and the relatedness requirement is satisfied when a 

company “serves a market for a product in the forum State and the 

product malfunctions there.” Id. at 1026–27. The Court cautioned, 

however, that its holding should not be read to suggest that “anything 

goes.” Id. at 1026. Rather, there must be “real limits” on the relatedness 
11 

inquiry that adequately protect the due-process rights of a foreign 

defendant. Id.

III. Analysis 

Neither LG Chem defendant disputes that it purposefully availed 

itself of the privilege of conducting activities in Texas through the sale, 

shipment, or distribution of model 18650 batteries to Texas 

manufacturers. Instead, they assert their contacts with Texas should 

not subject them to personal jurisdiction in this case because Morgan’s 

claims do not arise out of and are insufficiently related to their contacts. 

In particular, they emphasize that the evidence shows they “never 

sought to serve a consumer market for 18650 batteries” in Texas. 

The LG Chem defendants describe the batteries they 

manufacture, sell, and distribute as “industrial components”—power 

cells that are incorporated into battery-powered products like cordless 

power tools or laptop computers. Morgan, they contend, was injured by 

something else: a standalone battery marketed and sold to individuals 

as a “consumer product” by someone outside their intended chain of 

distribution. Because they target industrial manufacturers and not 

individual consumers like Morgan, the argument goes, Morgan’s claims 

are not sufficiently related to the defendants’ contacts with Texas to 

justify the exercise of personal jurisdiction. 

This Court has never endorsed the LG Chem defendants’ 

proposed granulation of the forum—the State of Texas—into distinct 

market segments when evaluating personal jurisdiction. Indeed, we 

recently described the minimum-contacts inquiry as “a ‘forum-by-forum’ 

or ‘sovereign-by-sovereign’ analysis that examines the nature and 
12 

extent of the defendant’s relationship to the forum.” State v. Volkswagen 

Aktiengesellschaft, ___ S.W.3d ___, 2023 WL 3262271, at *7 (Tex. May 5, 

2023) (cleaned up). The purpose of the personal-jurisdiction analysis is 

to determine whether the forum—the State of Texas—may exercise 

personal jurisdiction over a defendant consistent with due process. See

Bristol-Myers, 582 U.S. at 264 (“[T]here must be an ‘affiliation between 

the forum and the underlying controversy, principally, [an] activity or 

an occurrence that takes place in the forum State.’” (quoting Goodyear 

Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915, 919 (2011))). 

Rather than focusing on the nature and magnitude of their contacts with 

the sovereign forum and the close relationship of those contacts to this 

litigation, the LG Chem defendants urge us to shift focus to whether the 

plaintiff is within a particular Texas market segment—the “industrial 

component” market—they intended to serve. The minimum-contacts 

analysis is concerned with the objective existence, nature, and extent of 

the Texas contacts rather than the particulars of what the parties 

thought, said, or intended about the course their product might take 

after the defendant targeted, and the product entered, Texas. See

Moncrief Oil Int’l Inc. v. OAO Gazprom, 414 S.W.3d 142, 147 (Tex. 2013). 

Accordingly, here, the LG Chem defendants’ supposed intent to serve 

only industrial customers in Texas is of lesser importance than the 

larger and dispositive question: whether it would violate due process for 

Texas to exercise personal jurisdiction over the LG Chem defendants 
13 

when Morgan was injured by the very product—the model 18650 

lithium-ion battery—they sold and shipped to Texas by the thousands.4

This conclusion is inescapable given our precedents, which 

uniformly treat the whole forum—the entire state of Texas—as the 

relevant market in the minimum-contacts analysis. For example, in 

Luciano, we held that a defendant that sold insulation to manufacturers 

in Texas for installation in Texas homes was subject to personal 

jurisdiction for claims brought by Texas homeowners for the insulation’s 

alleged defects. With respect to the relatedness inquiry, we stated that 

“[i]t is sufficient that [the defendant] intended to serve a Texas market 

for the insulation that the [plaintiffs] allege injured them in this 

lawsuit.” Luciano, 625 S.W.3d at 17 (citing Ford, 141 S. Ct. at 1028); see 

also Searcy v. Parex Res., Inc., 496 S.W.3d 58, 67 (Tex. 2016) (“[S]pecific 

jurisdiction exists when the plaintiff’s claims arise out of or are related 

to the defendant’s contact with the forum.” (emphasis added) (internal 

quotations omitted)); Guardian Royal Exch. Assurance, Ltd. v. Eng. 

China Clays, P.L.C., 815 S.W.2d 223, 230 (Tex. 1991) (“When specific 

jurisdiction is asserted, the cause of action must arise out of or relate to 

the nonresident defendant’s contacts with Texas.” (emphasis added)). 

Here, the LG Chem defendants intended to serve the Texas 

market for their model 18650 batteries—the same model battery that 

Morgan alleges exploded in his pocket and injured him. The LG Chem 

4 As both sides acknowledge, information about the way Morgan used 

(or misused) the battery and whether the LG Chem defendants authorized that 

use may be relevant to the merits of Morgan’s products-liability claims. We 

express no opinion on whether it is or on any other aspect of the ultimate merits 

of Morgan’s claims. 
14 

defendants urge us to distinguish between the market of sophisticated 

manufacturers they targeted and the market of individual consumers 

like Morgan, which they did not target. But there is no requirement for 

jurisdictional purposes that the market segment the LG Chem 

defendants served be precisely the same one from which Morgan 

purchased the battery. The LG Chem defendants undisputedly sold and 

distributed model 18650 batteries in Texas, and they do not dispute that 

is the same model battery Morgan alleges injured him in Texas. That is 

sufficient to satisfy the relatedness prong and establish specific personal 

jurisdiction in Texas. Luciano, 625 S.W.3d at 17; see Ford, 141 S. Ct. at 

1028 (describing “a strong relationship among the defendant, the forum, 

and the litigation” as “the essential foundation” of specific jurisdiction 

(internal quotations omitted)); Moki Mac, 221 S.W.3d at 585 (stating 

that due process is satisfied where there is a “substantial connection” 

between the defendant’s contacts and the operative facts of the 

litigation). 

The LG Chem defendants argue that the Court’s analysis must 

focus on the absence of any intent to serve the market of individual 

consumers. Otherwise, they contend, they will be subject to jurisdiction 

without the clear notice that due process requires. See Ford, 141 S. Ct. 

at 1025 (stating that the Court’s personal-jurisdiction doctrine “provides 

defendants with ‘fair warning’—knowledge that ‘a particular activity 

may subject [it] to the jurisdiction of a foreign sovereign’” (alteration in 

original) (quoting Burger King Corp. v. Rudzewicz, 471 U.S. 462, 472 

(1985))). We disagree. As Ford teaches, “[a]n automaker regularly 

marketing a vehicle in a State . . . has ‘clear notice’ that it will be subject 
15 

to jurisdiction in the State’s courts when the product malfunctions 

there.” Id. at 1030 (citing World-Wide Volkswagen Corp. v. Woodson, 

444 U.S. 286, 297 (1980)). Texas’s exercise of personal jurisdiction over 

the LG Chem defendants for a claim based on a defective model 18650 

battery does not deprive them of due process simply because they may 

not have anticipated the claim would be brought by someone outside 

their intended chain of distribution. By selling and distributing model 

18650 batteries in Texas, the LG Chem defendants purposefully availed 

themselves of Texas and have enjoyed the benefits and protection of 

Texas laws. Id. at 1029 (citing Int’l Shoe, 326 U.S. at 319). Texas’s 

enforcement of the LG Chem defendants’ reciprocal obligation to ensure 

that its model 18650 batteries are safe for Texas citizens can “hardly be 

said to be undue.” Id. at 1030 (quoting Int’l Shoe, 326 U.S. at 319). 

The LG Chem defendants also assert that clear notice is lacking 

because they cannot structure their Texas-directed conduct to avoid 

exposure to consumer lawsuits such as Morgan’s other than by choosing 

not to sell its product in Texas at all. See id. (observing that clear notice 

of a state’s potential exercise of jurisdiction allows a defendant to 

structure its primary conduct to “lessen or even avoid the costs of 

state-court litigation”). But avoiding the Texas market altogether is not 

a defendant’s only option. Defendants can also “act to alleviate the risk 

of burdensome litigation by procuring insurance [or] passing the 

expected costs on to customers.” Id. at 1027 (quoting World-Wide 

Volkswagen, 444 U.S. at 297). 

Finally, we recognize multiple decisions of our courts of appeals, 

at least one Texas federal district court, and courts in other jurisdictions 
16 

involving factually similar claims against the LG Chem defendants or 

other battery manufacturers yielding seemingly conflicting conclusions 

about whether personal jurisdiction exists.5 The result in each case is, 

of course, dependent on the particular record before the court, including 

the evidence presented to establish the existence of both purposeful 

availment and relatedness. See Kulko v. Superior Ct., 436 U.S. 84, 92 

(1978) (“[T]he ‘minimum contacts’ test . . . is not susceptible of 

mechanical application; rather, the facts of each case must be weighed 

. . . .”); see also Ethridge v. Samsung SDI Co., 617 F. Supp. 3d 638, 652 

(S.D. Tex. 2022) (noting the defendant described the plaintiff’s evidence 

of the defendant’s battery shipments into Texas as “not only 

inadmissible and unpersuasive, but also paltry compared to” the 

evidence of LG Chem’s shipments in this case). While we disapprove of 

any reliance on the argument that the LG Chem defendants’ intent to 

serve the industrial versus the individual-consumer market segment for 

5 See, e.g., LG Chem, Ltd. v. Tullis, No. 05-21-01056-CV, 2022 WL 

16959264, at *6 (Tex. App.—Dallas Nov. 16, 2022, pet. filed) (affirming the 

trial court’s denial of LG Chem’s special appearance); LG Chem Am., Inc. v. 

Zapata, No. 14-21-00695-CV, 2022 WL 16559339, at *6 (Tex. App.—Houston 

[14th Dist.] Nov. 1, 2022, no pet.) (reversing the trial court’s denial of special 

appearances by LG Chem and LG Chem America); Hause v. LG Chem, Ltd., 

658 S.W.3d 714, 733 (Tex. App.—El Paso 2022, pet. filed) (reversing the trial 

court’s grant of LG Chem’s special appearance); Dilworth v. LG Chem, Ltd., 

355 So. 3d 201, 211 (Miss. 2022) (reversing the trial court’s dismissal of claims 

against LG Chem and LG Chem America but remanding the claim against LG 

Chem America for jurisdictional discovery); LG Chem, Ltd. v. Superior Ct., 

295 Cal. Rptr. 3d 661, 682 (Ct. App. 2022) (concluding that the plaintiff failed 

to establish the court’s personal jurisdiction over LG Chem); see also Ethridge 

v. Samsung SDI Co., 617 F. Supp. 3d 638, 653 (S.D. Tex. 2022) (concluding that 

a plaintiff alleging similar facts against a different nonresident battery 

manufacturer failed to establish the court’s personal jurisdiction over the 

defendant). 
17 

model 18650 batteries necessarily defeats relatedness, we express no 

opinion on whether these cases, each of which is accompanied by a 

unique evidentiary record, were correctly decided. 

IV. Conclusion 

LG Chem and LG Chem America do not dispute that they 

purposefully availed themselves of the privilege of doing business in 

Texas by selling and distributing their model 18650 batteries in Texas. 

Morgan alleges he was injured by a defective model 18650 battery 

manufactured by LG Chem. Despite the LG Chem defendants’ claim 

that they did not intend to serve a market for individual e-cigarette 

battery consumers such as Morgan, we hold that Morgan’s claims are 

sufficiently related to the LG Chem defendants’ undisputed contacts 

with Texas to satisfy due process. Because the LG Chem defendants are 

subject to specific personal jurisdiction in Texas in this case, we affirm 

the court of appeals’ judgment. 

 

 Rebeca A. Huddle 

 Justice 

OPINION DELIVERED: May 19, 2023