Personal Jurisdiction Lacking in Trade Secret Suit
June 2, 2013Voltaix is a New Jersey company that manufactures a specialty gas used in the semiconductor and solar energy industries. Voltaix alleged that two of its former employees at its New Jersey plant stole its trade secrets, moved to Texas, and started a competing company based in Texas named Metaloid Precursors. Voltaix sued these employees, their new company, and John Ajongwen (the chairman and a major investor in Metaloid) in Texas for, among other things, misappropriation of trade secrets. Ajongwen, however, filed a special appearance because, in his view, he was a New Jersey resident with no minimum contacts in Texas. The trial court agreed.
The Court of Appeals affirmed the trial court’s decision. It found that Ajongwen came to Texas only one time, for half a day, to oversee set up of the plant’s water purification system and to conduct a safety inspection of the plant. Because neither of these events had any connection with the trade secret misappropriation allegations, the court held Texas courts lacked personal jurisdiction over Ajongwen in this suit.
