No personal jurisdiction over alleged fraudulent transferee

In a fraudulent-transfer case, the Fifth Court reversed the denial of a German company’s special appearance when: “AEG Germany was not a party to the Manufacturing Agreement or the Security Agreement;it was not involved inthe “order process” with Power Max and AEG USA;nor was it a party to AEG USA’s lawsuit against Power Max. In fact, Creation has not alleged any contacts by AEG Germany with the state of Texas that ‘give rise’ to Creation’s claims against it, apart from the allegation that AEG Germany was the recipient of fraudulently transferred assets. . . . [A]s the above [“effects test”] cases show, even if we assume a tort was somehow committed and that AEG Germany knew its actions would cause an injury in Texas (assumptions this record does not support), the alleged contacts do not rise to the level of purposeful availment simply because Creation is a Texas company or the alleged harm occurred in Texas.” AEG Power Solutions v. Creation Technologies,  No. 05-19-00195-CV (Nov. 12, 2019) (mem. op.)