The defendant in Bowles v. Ranger Land Systems did not have a bank account, registered agent, or office in Texas. No. 12-51255 (June 16, 2013, unpublished). As a defense contractor, the company had a handful of employees at three Army bases in Texas, but that presence was not substantial enough to create general jurisdiction. (citing Johnston v. Multidata Systems Int’l Corp., 523 F.3d 602, 612-13 (5th Cir. 2008) (presence of two employees, who reported to out-of-state supervisor, was “certainly a regular contact with Texas” but was “not substantial enough to create a general business presence in Texas”)). The Fifth Circuit also found no abuse of discretion in denying further jurisdictional discovery based on these allegations.
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