State of Texas v. Arity 875, LLC

Opinion

ACCEPTED 15-25-00082-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 10/24/2025 3:28 PM CHRISTOPHER A. PRINE CLERK FILED IN 15th COURT OF APPEALS AUSTIN, TEXAS 10/24/2025 3:28:42 PM CHRISTOPHER A. PRINE October 24, 2025 Clerk

Christopher A. Prine Via File&Serve Texas Fifteenth Court of Appeals William P. Clements Building 300 W. 15th Street, Suite 607 Austin, Texas 78701

Re: Notice of Supplemental Authority, State v. Arity 875, LLC, (15-25-00082- CV)

Dear Mr. Prine,

Appellant, the State of Texas, submits this letter to give notice of new authority that may benefit the Court: State v. Yelp, Inc., No. 15-24-00040-CV, 2025 WL 2936466 (Tex. App. [15th Dist.] Oct. 16, 2025) (attached as Exhibit 1). Yelp supports the State’s position that Appellee Arity 875, LLC purposefully availed itself of Texas’ jurisdiction by offering targeted advertisements to Texas consumers through its proprietary software installed on Texas devices. See State Br. at 39–41.

In Yelp, this Court reviewed a dismissal for lack of personal jurisdiction from Yelp, Inc., a California-based website operator. Yelp lacked a physical presence in Texas but derived “revenue from the sales of customizable location specific advertising.” Yelp, 2025 WL 2936466 at *8. The Court found that the State demonstrated that Yelp did “substantial business” in Texas by alleging, in relevant part, that Yelp “purposefully direct[ed] tailored advertisements to Texas users” as well as “deriv[ed] revenue from the sales of customizable location specific advertising.” Id. As a result, this Court found Texas had specific personal jurisdiction.

Yelp supports the State’s position that Arity 875, LLC purposefully availed itself of Texas’ jurisdiction by targeting specific drivers in Texas for tailored advertisements based on their personal geolocation data, and the insights derived from such data. See State Br. at 40. Like in Yelp, the State alleges that Arity 875, LLC P os t Office Bo x 12548, Au stin , Tex as 7 8 7 1 1 - 2 5 4 8 • ( 5 1 2 ) 4 6 3 - 2 1 0 0 • www.tex as atto r neygene ra l.go v derives revenue from its purposeful presence in Texas through the sales of customizable, location-specific advertisements directed to Texas consumers. Id. Further, this case negates Arity 875, LLC’s position that sales of targeted advertisement positions to third parties seeking to advertise to Texas consumers do not constitute purposeful availment. Contra Arity 875 Br. at 33.

Respectfully submitted,

/s/ Richard R. McCutcheon

Richard R. McCutcheon Assistant Attorney General

cc: all counsel of record (via electronic filing) EXHIBIT 1 State v. Yelp, Inc., --- S.W.3d ---- (2025) 2025 WL 2936466

2025 WL 2936466 BACKGROUND Only the Westlaw citation is currently available. Yelp is an internet-based Delaware corporation with its NOTICE: THIS OPINION HAS NOT BEEN RELEASED principal place of business in San Francisco, California. Yelp FOR PUBLICATION IN THE PERMANENT essentially operates as an online “yellow pages,” 1 providing LAW REPORTS. UNTIL RELEASED, IT IS consumers in search of a service or product with lists of SUBJECT TO REVISION OR WITHDRAWAL. businesses that match the user's specifications, as well as Court of Appeals of Texas (15th Dist.). custom location-targeted ads, paid for by businesses. The consumer is then able to either book a reservation or purchase The STATE of Texas, Appellant a product in some cases. Consumers can post reviews about v. their experience with those businesses, subject to moderation YELP, INC., Appellee by Yelp. Other consumers using Yelp are then able to read the reviews. If a consumer books an appointment or reservation, NO. 15-24-00040-CV or purchases a product, Yelp generally derives revenue from | these services. In 2009, Yelp registered to conduct business Opinion filed October 16, 2025 in Texas as a foreign, for-profit corporation. Yelp listed its express purpose for transacting business in Texas as “Internet On Appeal from the 335th District Court, Bastrop County, Advertising.” Texas, Trial Court Cause No. 2519-335, Honorable Reva Towslee-Corbett, Judge Following the leak of the United States Supreme

Attorneys and Law Firms Court's decision in Dobbs v. Jackson Women's Health Organization, 597 U.S. 215, 142 S.Ct. 2228, 213 L.Ed.2d Catherine Lewis Robb, Laura Lee Prather, Austin, Michael J. 545 (2022), Yelp CEO Jeremy Stoppelman urged business Lambert, William R. Pillifant, for Appellee. leaders to use their “platform and influence” to help protect reproductive rights. Three months later, in August 2022, Yelp Abigail E. Smith, Rob Farquharson, Scott Froman, for posted a consumer notice on the Yelp business pages of Appellant. Crisis Pregnancy Centers across the nation. The notice stated, Before Chief Justice Brister and Justices Field and Farris. “This is a Crisis Pregnancy Center. Crisis Pregnancy Centers typically provide limited medical services and may not have licensed medical professionals onsite.”

OPINION By letter dated February 7, 2023, twenty-four state attorneys April Farris, Justice general, including Texas Attorney General Paxton, demanded that Yelp remove the notice and “stop discriminating” against *1 Yelp, Inc. filed a special appearance in response to Crisis Pregnancy Centers. The next day, Yelp responded by the State's petition seeking civil penalties, damages, and providing sources in support of its notice, but Yelp also injunctive relief for alleged violations of the Deceptive revised the notice to address the concerns raised in the letter. Trade Practices Act. The trial court granted Yelp's special The revised notice stated, “This is a Crisis Pregnancy Center. appearance and dismissed the State's case. On appeal, the Crisis Pregnancy Centers do not offer abortions or referrals State argues that this dismissal was erroneous because the to abortion providers.” State established both general and specific jurisdiction over Yelp in Texas. We hold that the State did not plead facts *2 On September 28, 2023, the State sued Yelp in Bastrop establishing general jurisdiction over Yelp, but the State has County, asserting that Yelp violated the Deceptive Trade established specific jurisdiction. Consequently, we reverse Practices Act by misleading Texas consumers about the the trial court's order of dismissal and remand the case for availability of medical services at Crisis Pregnancy Centers. adjudication on the merits. In response, Yelp filed a special appearance, arguing that the trial court lacked personal jurisdiction because (1) Yelp, as a

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nonresident, lacks sufficient minimum contacts with Texas to and specific jurisdiction. Moki Mac, 221 S.W.3d at 575. demonstrate purposeful availment of the Texas forum; (2) the General jurisdiction arises when a defendant's contacts with State's Deceptive Trade Practices claim does not arise from the forum state are so “continuous and systematic” that the Yelp's contacts with Texas; and (3) the exercise of jurisdiction over Yelp would offend traditional notions of fair play and defendant is “essentially at home.” State v. Volkswagen substantial justice. Aktiengesellschaft, 669 S.W.3d 399, 412 (Tex. 2023) (quoting Luciano v. SprayFoamPolymers.com, LLC, 625 S.W.3d 1, The State filed a response to the special appearance asserting 8 (Tex. 2021)). General jurisdiction permits courts to “render that Yelp had extensive contacts with Texas, which gave a binding judgment against a defendant even if the plaintiff's rise to both general and specific jurisdiction. The State claims neither arise from activities conducted in the forum also asserted that Yelp had consented to general jurisdiction state nor ‘relate to the forum [s]tate or the defendant's activity by registering to do business in Texas. The trial court granted Yelp's special appearance and dismissed the case with there.’ ” Id. (alteration in original) (quoting Ford Motor prejudice. This appeal followed. Co. v. Mont. Eighth Jud. Dist. Ct., 592 U.S. 351, 358, 141 S.Ct. 1017, 209 L.Ed.2d 225 (2021)). If general jurisdiction is established, the cause of action “may concern events and conduct anywhere in the world,” subject to certain limits. ANALYSIS Id. In two issues, the State contends that the trial court erred in granting Yelp's special appearance because (1) Yelp Courts can exercise specific jurisdiction over a nonresident consented to general jurisdiction in Texas as a condition of defendant, when (1) the defendant engages in some act registering to do business in the state; and (2) Yelp is subject to by which it purposefully avails itself of the privilege of specific jurisdiction in Texas because it purposefully availed conducting activities within the state and (2) the plaintiff's itself of the Texas forum, and the State's claims are related to claims arise out of or relate to those forum contacts. LG those purposeful contacts with Texas. Chem Am., 670 S.W.3d at 347. Purposeful availment and relatedness are “two co-equal components.” Id. (quoting I. Standard of Review Moki Mac, 221 S.W.3d at 579). There must be an A nonresident defendant is subject to the personal jurisdiction appropriate “nexus between the nonresident defendant, the of Texas courts if (1) the Texas long-arm statute authorizes the court to exercise jurisdiction, and (2) exercising jurisdiction litigation, and the forum.” Moki Mac, 221 S.W.3d at 579. does not violate state and federal constitutional due process The plaintiff “must demonstrate a ‘substantial connection’ between the defendant's contacts and the operative facts of guarantees. LG Chem Am., Inc. v. Morgan, 670 S.W.3d 341, 346 (Tex. 2023) (citing Tex. Civ. Prac. & Rem. Code the litigation.” LG Chem Am., 670 S.W.3d at 347 (quoting

§§ 17.041–.045); Kelly v. Gen. Interior Const., Inc., 301 Moki Mac, 221 S.W.3d at 585). S.W.3d 653, 657 (Tex. 2010). The requirements of the long- arm statute “are satisfied if an assertion of jurisdiction accords *3 Whether a court has personal jurisdiction over a party is

with federal due-process limitations.” Moki Mac River a question of law that we review de novo. Id. at 346. When Expeditions v. Drugg, 221 S.W.3d 569, 575 (Tex. 2007). the trial court does not issue findings of fact and conclusions Personal jurisdiction “is consistent with due process ‘when of law, as is the case here, “we presume all factual disputes the nonresident defendant has established minimum contacts were resolved in favor of the trial court's decision unless with the forum state, and the exercise of jurisdiction comports they are challenged on appeal.” Mehta v. State ex rel. Ahmed, with traditional notions of fair play and substantial justice.’ 716 S.W.3d 186, 191 (Tex. App.—15th Dist. 2025, no pet.)

” Kelly, 301 S.W.3d at 657 (quoting Moki Mac, 221 (quoting Luciano, 625 S.W.3d at 8). S.W.3d at 575).

II. The State Did Not Plead Allegations Sufficient to The nonresident defendant's forum-state contacts can give Establish General Jurisdiction. rise to two types of personal jurisdiction—general jurisdiction

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In the State's first issue, the State asserts that Yelp consented to general jurisdiction in Texas by registering to do business to general jurisdiction in Texas as a condition of registering in Texas. On appeal, Yelp argues that although a response to a special appearance may contain evidence supporting the to do business in the state, citing Mallory v. Norfolk S. petition's allegations, the allegations on which the plaintiff Ry. Co., 600 U.S. 122, 143 S.Ct. 2028, 216 L.Ed.2d 815 bases the exercise of jurisdiction must be in the petition. The (2023) and Section 9.203 of the Texas Business Organizations State argues that it was sufficient to raise these sources of Code. In Mallory, the United States Supreme Court jurisdiction in its response to Yelp's plea to the jurisdiction, addressed a Pennsylvania statute requiring all corporations and that the State need not have pleaded either Mallory or that registered to do business in Pennsylvania to consent to Texas Business Organizations Code Section 9.203 as the basis personal jurisdiction in Pennsylvania in exchange for status for an exercise of general jurisdiction. as a foreign corporation. Mallory, 600 U.S. at 126–27, 143 S.Ct. 2028. The Supreme Court determined that this We agree with Yelp. The Rules of Civil Procedure require statute—which conferred general personal jurisdiction on courts to determine a special appearance on the “basis of Pennsylvania courts over registered foreign corporations— the pleadings, any stipulations made by and between the did not violate the U.S. Constitution's Due Process Clause. parties, such affidavits and attachments as may be filed by Id. at 146, 143 S.Ct. 2028. the parties, the results of discovery processes, and any oral testimony.” Tex. R. Civ. P. 120a(3) (emphasis added). The The State argues that Section 9.203 of the Texas Business Texas Supreme Court has “consistently held that the plaintiff Organizations Code functions just like the Pennsylvania bears the initial burden to plead sufficient allegations to bring the nonresident defendant within the reach of Texas's long- statute in Mallory, making every foreign corporation consent to personal jurisdiction in Texas as a condition of arm statute.” Kelly, 301 S.W.3d at 658; LG Chem Am., registering as a foreign corporation. That provision states, in 670 S.W.3d at 346 (noting that for a special appearance, “[t]he relevant part: plaintiff bears the initial burden to plead sufficient allegations to bring the nonresident defendant within the reach of the long-arm statute.”). “The nonresident ‘defendant then bears the burden to negate all bases of personal jurisdiction alleged in any matter that affects the by the plaintiff,’ ” an exercise that typically requires evidence. transaction of intrastate business in this state, a foreign entity and each Mehta, 716 S.W.3d at 191 (quoting LG Chem Am., 670 member, owner, or managerial official S.W.3d at 346). But when the Plaintiff's pleadings fail to of the entity is subject to the same contain facts bringing the defendant within the reach of the duties, restrictions, penalties, and long-arm statute, then the “defendant need only prove that it liabilities imposed on a domestic entity does not live in Texas to negate jurisdiction.” Kelly, 301 to which it most closely corresponds S.W.3d at 659. or on a member, owner, or managerial official of that domestic entity. *4 Under this burden shifting framework, the plaintiff's pleadings set the boundaries for what types of evidence and arguments may be offered either for or against jurisdiction. Tex. Bus. Orgs. Code § 9.203. Although the pleadings themselves may not be dispositive of jurisdiction when the defendant contests those pleadings Yelp disputes that the Texas Business Organizations Code with evidence, the “additional evidence merely supports or vests Texas courts with general jurisdiction over all foreign corporations registered in Texas. Regardless, Yelp argues that undermines the allegations in the pleadings.” Id. at 658 we cannot consider this statute as a basis for conferring n.4. In other words, “[b]ecause the plaintiff defines the scope general jurisdiction because the State did not mention either and nature of the lawsuit, the defendant's corresponding burden to negate jurisdiction is tied to the allegations in the Section 9.203 or Mallory in its live pleadings. Rather, the State waited until its response to Yelp's plea to the plaintiff's pleading.” Id. at 658. If the plaintiff's evidence jurisdiction to assert, for the first time, that Yelp consented is not within the scope of the pleadings’ factual allegations,

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then “the plaintiff should amend the pleading to include the negate only those factual bases for personal jurisdiction that are stated in the plaintiff's pleadings—not those asserted necessary factual allegations.” Id. at 659. elsewhere, such as in a response to a plea to the jurisdiction. See, e.g., Texas Bank & Tr. v. California Coast Credit Union, We hold that Kelly controls here and compels the No. 12-24-00149-CV, 2025 WL 657280, at *10 (Tex. App. conclusion that the State must meet its initial burden on —Tyler Feb. 28, 2025, no pet.) (mem. op.) (refusing to a special appearance by pleading in its petition sufficient credit an indemnification agreement as a basis for personal allegations to invoke jurisdiction. See id. at 658 (requiring jurisdiction where the plaintiff never amended its pleadings to the factual bases supporting the exercise of jurisdiction to invoke that agreement as a basis for jurisdiction); Witty Yeti, be in the petition). We are aware of contrary authority in LLC v. Plummer, No. 04-22-00075-CV, 2022 WL 3046942, which other courts of appeals have concluded that Rule 120a at *5 (Tex. App.—San Antonio Aug. 3, 2022, no pet.) contemplates considering jurisdictional allegations made in (mem. op.) (“If the plaintiff fails to plead facts to bring the the plaintiff's response, but these decisions are not consistent defendant within the reach of the court's jurisdiction, the defendant need only prove that it does not live in Texas with Kelly's reasoning. 2 to negate personal jurisdiction. Once the plaintiff has met its burden to plead sufficient jurisdictional allegations, the We are not alone in interpreting Kelly to require the burden shifts to the defendant to negate all potential bases for allegations supporting jurisdiction to be included in the personal jurisdiction that exist in the plaintiff's pleadings.”) petition. The en banc Fifth Court of Appeals has reached the (citing Kelly, 301 S.W.3d at 658–59). The Texas Business same conclusion, holding that “[t]he plaintiff's response to the special appearance may contain evidence supporting the Court, too, has followed Kelly on this point. Riverside petition's jurisdictional allegations, but that evidence must be Strategic Cap. Fund I, L.P. v. CLG Investments, LLC, No. 25-BC01B-0006, 2025 WL 2419620, at *7 ¶ 45 consistent with the allegations in the petition.” Steward (Tex. Bus. Ct. Aug. 19, 2025) (“Riverside's arguments and Health Care System LLC v. Saidara, 633 S.W.3d 120, 129 evidence opposing the special appearance do not save it. The (Tex. App.—Dallas 2021, no pet.) (en banc). Interpreting court considers only allegations in plaintiffs’ petition—not Kelly, the Steward court held that “the allegations on allegations made in its response—and considers additional which the plaintiff bases the exercise of jurisdiction must be evidence only to the extent it supports or undermines those in the petition,” as “nothing in the supreme court's precedent allegations.”) (citing Kelly, 301 S.W3d at 658–59, and suggests the defendant must negate jurisdictional allegations appearing only in the response to the special appearance.” Steward, 633 S.W.3d at 129). We join these courts in refusing to consider factual grounds for jurisdiction that are Id. The Court resolved that “[t]o be consistent with not asserted in the plaintiff's pleadings. Kelly, we conclude that the plaintiff must meet its burden on a special appearance by pleading, in its petition, sufficient In this case, the State did not raise its argument that the allegations to invoke jurisdiction under the Texas long-arm Texas Business Organizations Code created jurisdiction by consent until the State filed its response to Yelp's plea to the statute.” Id. (overruling the court's prior opinions to the jurisdiction. This ground for jurisdiction does not appear in extent that they conflicted with this conclusion). Because the jurisdiction-conferring allegations appeared only in the the pleadings, so we do not consider it. 3 plaintiffs’ response to the plea to the jurisdiction and not their We instead review the factual assertions in the pleadings live pleadings, the Steward Court held that the plaintiffs to determine whether the State met its burden of pleading had not pleaded sufficient allegations to bring the defendant sufficient allegations to establish that Yelp's continuous and within the provisions of the Texas long-arm statute. Id. at systematic contacts render it essentially “at home” in Texas. 131. See Volkswagen, 669 S.W.3d at 412. The State's original petition alleged that Yelp is a Delaware corporation with *5 Since Steward issued, many of our sister intermediate its principal place of business in California. The State provided that Yelp could be served with process by serving courts have followed Kelly in requiring defendants to its registered agent located in Dallas, Texas. The State did

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not plead that Yelp consented to general jurisdiction by is consistent with federal due-process limitations. Moki registering to do business in Texas. Nor did the State plead Mac, 221 S.W.3d at 575. anything about Mallory or Texas Business Organizations Code Section 9.203. The State relied on the affidavits, Federal due-process requirements are satisfied when the discovery materials, and other evidence attached to its nonresident defendant has established minimum contacts response. Attached to the State's response was a copy of with the forum state and the exercise of jurisdiction comports Yelp's application to register as a foreign non-profit in Texas. with traditional notions of fair play and substantial justice. This evidence, however, was not in support of any pleading See Int'l Shoe Co. v. Washington, 326 U.S. 310, 316, 66 that Yelp had consented to general jurisdiction. See Certain Underwriters at Lloyd's, London v. Henry Vogt Mach. Co., S.Ct. 154, 90 L.Ed. 95 (1945); Volkswagen, 669 S.W.3d at Inc., 712 S.W.3d 909, 919 (Tex. App.—Houston [14th Dist.] 412. Minimum contacts exist when the nonresident defendant 2025, no pet.) (“These allegations appear to address service purposefully avails itself of the privilege of conducting of process, not consent to personal jurisdiction.”). activities within the forum state, thus invoking the benefits and protections of its laws. Michiana Easy Livin’ Country, *6 Because the State did not plead sufficient allegations to Inc. v. Holten, 168 S.W.3d 777, 784 (Tex. 2005). support its theory of Yelp's consent to general jurisdiction, we conclude the State failed to establish general jurisdiction. 4 There are three components to the “purposeful availment” We overrule the State's first issue. inquiry. Searcy v. Parex Res., Inc., 496 S.W.3d 58, 67 (Tex. 2016). First, only the defendant's contacts with the III. The State Met Its Burden to Plead and Establish forum are relevant, not the unilateral activity of another Specific Jurisdiction. party or a third person. Id. Second, the contacts relied In its second issue, the State contends the trial court erred upon must be purposeful rather than random, fortuitous, in granting Yelp's special appearance because the State has isolated, or attenuated. Id. Third, the defendant must seek pleaded sufficient facts to demonstrate specific personal some benefit, advantage, or profit by availing itself of the jurisdiction over Yelp in Texas. According to the State, Yelp purposefully availed itself of the Texas forum and the State's jurisdiction. Id. Specific jurisdiction is established if the claims are related to those purposeful contacts. claims in question arise from or relate to the defendant's purposeful contacts with Texas. See Volkswagen, 669 Specific jurisdiction, as opposed to general jurisdiction, S.W.3d at 412–13. covers defendants who are less intimately connected with the forum state, but with respect to limited kinds of claims. *7 In conducting a specific-jurisdiction analysis, we focus Volkswagen, 669 S.W.3d at 412. Texas courts may exercise on the relationship among the defendant, the forum, and the personal jurisdiction over a nonresident if the Texas long- litigation. Kelly, 301 S.W.3d at 658. For a nonresident arm statute authorizes the exercise of personal jurisdiction and defendant's contacts with Texas to support an exercise of the exercise is consistent with federal and state constitutional specific jurisdiction, there must be a substantial connection due-process guarantees. Moki Mac, 221 S.W.3d at 574; between the defendant's contacts with the forum state and the see also Tex. Civ. Prac. & Rem. Code § 17.042 (Texas long- operative facts of the litigation. Moki Mac, 221 S.W.3d arm statute). The Texas Supreme Court has consolidated at 585. The operative facts are those facts that would be the these inquiries, holding that the Texas long-arm statute's focus of a trial on the merits. Law Firm of Donald Wochna, broad language allows Texas courts to exercise personal LLC v. Am. Frontier Mgmt., No. 03-17-00489-CV, 2018 WL jurisdiction as far as the Due Process Clause of the Federal 1614782, at *4 (Tex. App.—Austin April 4, 2018, pet. ref'd) Constitution permits. Volkswagen, 669 S.W.3d at 412; (mem. op.). BMC Software Belgium, N.V. v. Marchand, 83 S.W.3d 789, 795 (Tex. 2002). The requirements of the Texas long-arm A. The State Met its Burden to Sufficiently Plead statute thus are fulfilled if an assertion of personal jurisdiction Specific Jurisdiction.

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The Texas long-arm statute broadly permits a court to exercise users across the country to share information about their jurisdiction over a foreign corporation who does “business communities” and maintained no technology infrastructure in this state.” Tex. Civ. Prac. & Rem. Code § 17.042. The in Texas. Yelp further asserted all decisions concerning State's original petition alleged that Yelp is “a company” the disclaimer for Crisis Pregnancy Centers were made in that maintains a “platform in which users can connect California. with businesses by publishing online public reviews.” Crisis Pregnancy Centers, which “are located throughout the State *8 The State responded with evidence including (1) of Texas, including Bastrop County,” are one such business. images of Yelp's webpages; (2) copies of news articles The State alleged that Yelp “violated Texas law” by posting regarding Yelp; (3) Yelp's Texas Secretary of State filings; (4) a false, misleading, and disparaging disclaimer on the Yelp publications of Yelp's terms of service, social media posts, business pages of every pregnancy center across the nation. letter to shareholders, and investor presentations; and (5) This allegation included Crisis Pregnancy Centers in Texas Yelp's discovery responses. because the State alleged that (1) the “transactions forming the basis of this suit occurred in Bastrop County, Texas” and Due to its internet-based business model, Yelp has no need (2) Yelp “has done business in Bastrop County, Texas.” for a physical presence in Texas—or in most other states for that matter. However, it hires and retains remote employees These doing-business pleadings were sufficient to allege that in Texas. Nevertheless, the record reflects that Yelp derives Yelp is subject to specific jurisdiction under Texas's long- benefits in the form of revenue from the sales of customizable location specific advertising, and from any reservations or arm statute. See Steward, 633 S.W.3d at 126 (plaintiff's other purchases made through Yelp. The State established pleading requirement is satisfied by an allegation that the through evidence in support of its response that Yelp does nonresident defendant is doing business in Texas). substantial business in Texas, accesses and generates profits from Texans who book reservations or purchase items through B. The Asserted Contacts are Sufficient to Show Yelp pages, and purposefully directs tailored advertisements that Yelp Purposely Availed Itself of the Privilege of to Texas users. The State asserted that when a consumer Conducting Activities in Texas. searches Yelp's website Yelp uses the consumer's location Once the State satisfied its initial burden to plead allegations to show business pages for local Texas providers within sufficient to bring Yelp within the reach of Texas's long- the consumer's geographic area. Yelp also tracks consumers’ arm statute, the burden flipped to Yelp to negate all bases keyword searches and uses that information to facilitate paid advertisements. of personal jurisdiction in the State's pleading. Kelly, 301 S.W.3d at 658. Here, the State pleaded that Yelp is an internet- based company that “features a platform in which users can The State cites Siskind v. Villa Found. for Educ., Inc., connect with businesses by publishing online public reviews 642 S.W.2d 434 (Tex. 1982) in support of its argument that of those businesses on a publicly accessible page that Yelp Yelp purposely availed itself of jurisdiction in Texas. In maintains.” According to Yelp, its platform contains “trusted Siskind, the Texas Supreme Court held that exercise of local business information, photos and review content.” Yelp personal jurisdiction was proper over Villa—a school for placed a disclaimer on its platform on the pages of Crisis troubled children located in Arizona that solicited business in Pregnancy Centers across the nation, including in Bastrop County. Texas. Id. at 435, 437. Siskind, a Texas resident, sued Villa on the theory that he had paid tuition for his son to attend Villa In Yelp's special appearance, Yelp argued that there was no with the understanding from the modified enrollment contract basis for exercising personal jurisdiction because Yelp is a that Siskind would be reimbursed if his son left during the California-based website operator with no offices in Texas. school year. Id. at 435–36. Villa expelled Siskind's son and Yelp argued the State failed to establish general or specific refused to refund the tuition. Id. at 435. Siskind sued the jurisdiction because the State failed to allege the disclaimer school in Texas for breach of contract, misrepresentation, and was purposely directed at Texas, only that Yelp targeted Crisis Pregnancy Centers nationwide. Yelp asserted it “owns and violation of the Deceptive Trade Practices Act. Id. at 435– operates a local search website (available at Yelp.com), a 36. mobile website, and related mobile applications that allow

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In holding that Villa had personally availed itself of the S.W.3d at 792. The Texas Supreme Court rejected the argument, holding that a forum-selection clause does not Texas forum, the Siskind Court noted that a significant foreclose the possibility that the defendant had minimum number of Villa's students were Texas residents, and that the school advertised in the El Paso, Houston, and Lubbock contacts elsewhere. Id. As the Supreme Court explained, telephone directories as well as solicited business in a number the clause generally “operates as consent to jurisdiction in one forum, not proof that the Constitution would allow no other.” of national publications that were circulated in Texas. Id. at 435. The Supreme Court held that Villa's advertisements, Id. Regardless of the clause's enforceability in this case “in conjunction with its practice of mailing informational (an issue not before us), it does not prevent the exercise of packets, applications for admission, invitations to re-enroll, personal jurisdiction in Texas. and enrollment contracts to Texas residents,” indicated that Second, Yelp argues that it has not purposefully availed the school had affirmatively sought business in Texas. Id. itself of the forum because it did not make any money from at 436. the representations contained in its Consumer Notice. It is undisputed that Yelp does not allow any business categorized Here, Yelp does not need to send brochures through the as a Crisis Pregnancy Center to purchase any services offered mail or advertise in conventional telephone directories, but by Yelp, whether the business is located in Texas or elsewhere seeks consumers by sending targeted advertising based on in the United States. Further, Yelp does not conduct any trade where those consumers live. Yelp also engaged in additional or commerce with any business that is categorized as a Crisis conduct, such as creating independent pages for different Pregnancy Center, whether in Texas or anywhere else in the cities in Texas. The State introduced evidence of Yelp pages United States, and makes no money off Crisis Pregnancy advertising medical practices in Austin in addition to images Centers, directly or indirectly. Yelp argues that rather than of Yelp pages targeted to Dallas, Austin, Houston, and San seek any advantages from Texas, Yelp posted the Consumer Antonio. While the method of delivery is not the same as Notice to better inform consumers across the country about in Siskind, like the defendant in Siskind, Yelp actively businesses that they may choose to visit. solicited business in Texas. The fact that Yelp did not profit from the Consumer Notice *9 Yelp makes two other arguments for why it did not itself does not preclude a finding of personal jurisdiction purposefully avail itself of the privilege of doing business based on Yelp's availment of the Texas forum. Neither in Texas. First, Yelp argues that it purposefully avoided the the Texas Supreme Court nor the U.S. Supreme Court has privilege by including a forum selection clause and choice- conditioned a personal availment finding on whether the of-law provision in its online user agreement. A defendant defendant profited from the communication directed toward may “purposefully avoid a particular forum by structuring its the forum. The State is suing Yelp on a Deceptive Trade transactions in such a way as to neither profit from the forum's Practices claim, a claim for which no financial loss need be laws” nor subject itself to the forum's jurisdiction. Moki shown in order to recover. Mother & Unborn Baby Care of N. Tex., Inc. v. State, 749 S.W.2d 533, 538 (Tex. App. Mac, 221 S.W.3d at 575 (citing Burger King Corp. v. —Fort Worth 1988, writ denied) (“It is immaterial whether Rudzewicz, 471 U.S. 462, 472, 105 S.Ct. 2174, 85 L.Ed.2d appellants provided a service in exchange for money; the 528 (1985)). In support of this argument, Yelp attached to statute as a whole supports the conclusion that transfer of its special appearance a fifteen-page user agreement that valuable consideration is not necessary.”). Moreover, the required any claim, cause of action, request for relief, or State has raised a fact issue on whether Yelp might make dispute that might arise between the consumer and Yelp to money from data harvesting on user searches for Crisis be resolved by arbitration. Any claims that could not be Pregnancy Centers. arbitrated were required to be brought in courts located in San Francisco County, and California law would govern the terms We conclude the State's allegations coupled with the evidence of the agreement. attached to its response are sufficient to establish that Yelp purposefully availed itself of the privilege of conducting In Michiana, the defendant cited a similar forum-selection business in Texas, and that Yelp did not negate the State's allegations. Yelp's business contacts with Texas are thus clause as a basis for granting its special appearance. 168

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not the kinds of “random, isolated, or fortuitous” ones that That inquiry is satisfied here. Here, the State alleged that Yelp, will save a company from personal jurisdiction in a State using location data, appended a misleading disclaimer to the business pages of over 200 Crisis Pregnancy Centers in Texas notwithstanding its contacts with it. Ford Motor Co., 592 and “divert[ed] consumers from seeking [Crisis Pregnancy U.S. at 359, 141 S.Ct. 1017 (quoting Keeton v. Hustler Centers’] services in favor of other facilities that lacked the Magazine, Inc., 465 U.S. 770, 774, 104 S.Ct. 1473, 79 misleading disclosure.” Accordingly, the State's claim “arises L.Ed.2d 790 (1984)). Rather, Yelp “deliberately ‘reached from an injury which occurred in the forum state”—which out beyond’ its home” by appending the Consumer Notice is a “relevant part of the relatedness prong of the analysis.” to Crisis Pregnancy Centers in Texas. We therefore turn to Luciano, 625 S.W.3d at 17. 5 the question of whether the State established a substantial connection between Yelp's contacts and the operative facts of Yelp makes two responses for why the relatedness prong the litigation. nevertheless is unsatisfied here. First, Yelp responds that the required relatedness nexus is not satisfied because the C. Yelp's Contacts with Texas are Related to the disclaimer at the heart of the State's claim was published Operative Facts of the Litigation. nationwide and not sent specifically to any Texas consumer. *10 The State's Deceptive Trade Practices claim is premised According to Yelp, because Yelp targeted Crisis Pregnancy on allegations that Yelp directly appended misleading Centers everywhere, it cannot be said to have targeted Texas statements about Texas Crisis Pregnancy Centers to the specifically. We disagree. The fact that Yelp targeted Crisis business pages of over 200 Texas Crisis Pregnancy Centers, Pregnancy Centers outside Texas as well as in Texas does including in the district where this suit was brought—Bastrop not preclude us from finding the relatedness inquiry to be County. Yelp responds that the relevant decisions at issue satisfied. The Texas Supreme Court recently rejected an were made by Yelp employees in California. Those decisions analogous argument, holding that a “defendant need not included whether to create the Crisis Pregnancy Center single Texas out in some unique way to satisfy constitutional business category and whether to place disclaimers on Crisis dictates.” Volkswagen, 669 S.W.3d at 420. Rather, the Pregnancy Centers. The United States Supreme Court has “critical inquiry is whether a nonresident defendant has recognized that the relatedness inquiry, however, does not established sufficient contacts with Texas—not whether those require a causal connection. See Ford Motor Co., 592 U.S. contacts are materially different from its contacts with other at 361–62, 366 (holding that car manufacturer was subject states.” Id. at 421. A contrary rule would create perverse to specific jurisdiction in Montana and Minnesota on claims incentives, encouraging actors to commit harms everywhere for car-wreck injuries suffered there because manufacturer had advertised, sold, and serviced the relevant car models “in to avoid being haled into court anywhere. See id. Here, both States for many years,” even though the manufacturer as in Volkswagen, “there was no happenstance to [Yelp's] did not sell the specific cars involved in the litigation in those contacts with Texas.” Id. at 420. Yelp's conduct reflects states). Instead, the relatedness inquiry requires only that the intent to avail itself of several markets nationwide, including suit arise out of or relate to the defendant's contact with the Texas. Yelp's contacts in Texas are related to the operative forum. Id. at 362; see Volkswagen, 669 S.W.3d at 431 facts of the litigation; the fact that Yelp did not single out (determining that “[r]elationships may ‘support jurisdiction Texas does not defeat specific jurisdiction. Id. without a causal showing’ even when the litigation merely relates to the defendant's forum contacts.”) (quoting Ford Second, Yelp argues that the State's primary authorities do not Motor Co., 592 U.S. at 362, 141 S.Ct. 1017); Luciano, 625 involve internet transactions, and that this distinction compels S.W.3d at 17 (refusing to condition specific jurisdiction on a different result. See Ford, 592 U.S. at 366 n.4, 141 a “strict causal connection,” and instead finding it sufficient S.Ct. 1017 (excluding internet transactions from the product- that SprayFoam “intended to serve a Texas market for the liability case analysis because internet transaction cases insulation that the Lucianos allege injured them in this “may raise doctrinal questions of their own.”). According lawsuit.”). to Yelp, although Ford rejected a “strict causal theory” of relatedness, “it did not say that ‘anything goes.’ ” Johnson

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v. TheHuffingtonPost.com, Inc., 21 F.4th 314, 324 (5th Cir. Accordingly, the Fifth Circuit held that it lacked jurisdiction 2021) (quoting Ford Motor Co., 592 U.S. at 362, 141 over HuffPost with respect to Johnson's libel claim. Id. S.Ct. 1017). Yelp invokes the Fifth Circuit's directive in at 325. This case is unlike Johnson in all key respects: Johnson that “a plaintiff must link the defendant's suit- jurisdiction does not turn on mere website accessibility, but related conduct to the forum. Mere market exploitation will rather “internet activity was intended to target and focus on the forum.” Wakefield, 449 S.W.3d at 188. Here, Yelp not suffice.” Id. In Johnson, the Fifth Circuit held that expressly acknowledges that, while some people come to Yelp merely making a website “that's visible in Texas, of course, to find businesses that offer the pregnancy resources that does not suffice” to confer specific jurisdiction. Id. at 320; Crisis Pregnancy Centers provide, there are others who turn see Admar Int'l, Inc. v. Eastrock, L.L.C., 18 F.4th 783, 785 to Yelp to find reliable information about abortion providers, (5th Cir. 2021) (“Merely running a website that is accessible and that Yelp issued the Consumer Notice to help consumers in all 50 states, but that does not specifically target the make informed decisions. Here, the Consumer Notice was forum state, is not enough to create the ‘minimum contacts’ appended to Texas Crisis Pregnancy Centers, the customers necessary.”); Wakefield v. British Med. Journal Publ'g Group, of which are likely to be Texans. This is enough to establish Ltd., 449 S.W.3d 172, 188 (Tex. App.—Austin 2014, no the relatedness prong. 6 pet.) (“[T]he plaintiff must establish that the nonresident defendant's internet activity was intended to target and focus on the forum.”). D. Exercise of Personal Jurisdiction over Yelp Comports with Traditional Notions of Fair Play and *11 We agree with Yelp that “not anything goes” with Substantial Justice. respect to establishing specific jurisdiction over a company Once minimum contacts have been established, we must for its internet activities. But nor is the internet an invisibility consider whether, for other reasons, exercising jurisdiction cloak that prevents an actor from being haled into court over the nonresident defendant would offend “traditional in a given state simply because the actor used the internet notions of fair play and substantial justice.” Int'l Shoe, in the course of targeting its activity at Texas. Here, Yelp 326 U.S. at 316, 66 S.Ct. 154. Rarely will properly exercised took specific actions to target its communication at persons jurisdiction be found to impair fair play and substantial who were seeking help from Texas Crisis Pregnancy Centers. justice. Luciano, 625 S.W.3d at 18. We consider Yelp's Yelp appended the Consumer Notice—which contains the contacts with Texas in light of (1) the burden on the defendant; statements that the State contends are misleading—about (2) the interests of the forum in adjudicating the dispute; (3) Texas Crisis Pregnancy Centers to the business pages of over the plaintiff's interest in obtaining convenient and effective 200 Texas Crisis Pregnancy Centers, including in the district relief; (4) the interstate judicial system's interest in obtaining where this suit was brought—Bastrop County. It is undisputed the most efficient resolution of controversies; and (5) the that the Consumer Notice at issue here was viewable only on shared interest of several states in furthering fundamental “relevant Yelp pages”—in other words, the business listings for Crisis Pregnancy Centers, including the Texas locations. substantive social policies. Id. at 18–19.

*12 There is no undue burden placed upon Yelp by These facts distinguish this case from Johnson. In exercising jurisdiction. Yelp enjoys benefits and privileges Johnson, the plaintiff sued about a story that was posted on when conducting business in Texas, which are accompanied HuffPost's general news website. The site was “interactive,” by the corresponding obligation to answer suits that may but its story about Johnson had “no ties to Texas”; did “not arise from that business. Id. at 19 (“[T]o the extent that mention Texas”; recounted “a meeting that took place outside a corporation exercises the privilege of conducting activities Texas,” and “it used no Texan sources.” Johnson, 21 F.4th within a state, it enjoys the benefits and protection of the laws at 319. The Court further recognized that the mere fact that the of that state.”) (quoting Int'l Shoe, 326 U.S. at 319, 66 S.Ct. website was accessible in Texas was the only possible basis 154). for haling HuffPost into Texas courts, as HuffPost had not otherwise purposefully availed itself of Texas. Id. at 320.

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the letter sent to Yelp, several states share Texas's interest in Yelp asserts that it will be burdensome for it to litigate this ensuring that Crisis Pregnancy Centers are not the targets of case in Texas because all of its witnesses and documents are located in California. The burden to litigate in Texas, actionable misleading statements, assuming arguendo that the however, is lessened by modern travel and technology. State's allegations are meritorious. We conclude exercising jurisdiction over Yelp does not offend notions of fair play and See id.; Moncrief Oil Intern. Inc. v. OAO Gazprom, substantial justice. We sustain the State's second issue. 414 S.W.3d 142, 155 (Tex. 2013) (“Distance alone cannot ordinarily defeat jurisdiction.”). Yelp also contends that the State's interest in the litigation is lessened because it has not named a specific consumer who has been harmed by Yelp's CONCLUSION actions. The State, however has a strong interest in exercising Having determined that Yelp is subject to specific jurisdiction jurisdiction to protect its citizens from activities that may in Texas, we reverse the trial court's order granting Yelp's violate the Deceptive Trade Practices Act. See Luciano, special appearance and remand this case to the trial court. 625 S.W.3d at 19 (“[B]y virtue of the Legislature's enactment of the Deceptive Trade Practices Act, ... Texas has demonstrated a special interest in protecting its citizens All Citations from the sort of activity alleged here.”). Furthermore, as --- S.W.3d ----, 2025 WL 2936466 evidenced by the number of attorneys general who signed

Footnotes

1 Back when phones were still tethered to walls and not yet unleashed to dominate society, Americans typically owned hard-copy “telephone books.” In those telephone books, the “yellow pages” were the section— readily identifiable by the yellow hue of the paper—listing “business and professional firms alphabetically by category and that include[ed] classified advertising.” Yellow Pages, MERRIAM-WEBSTER.COM, https:// www.merriam-webster.com/dictionary/yellow% 20pages (last visited 4 Oct. 2025).

2 See e.g., Patel v. Pate, No. 02-16-00313-CV, 2017 WL 2871684, at *5 n.4 (Tex. App.—Fort Worth July 6, 2017, no pet.) (mem. op.); Sembcorp Marine Ltd. v. Carnes, Nos. 09-15-00430-CV, 09-15-00484-CV, 2016 WL 3019552, at *2 (Tex. App.—Beaumont May 26, 2016, no pet.) (mem. op.); Mi Gwang Contact Lens Co. v. Chapa, No. 13-13-00306-CV, 2015 WL 3637846, at *3 n.2 (Tex. App.—Corpus Christi–Edinburg June 11, 2015, no pet.) (mem. op.); Accelerated Wealth, LLC v. Lead Generation & Mktg., LLC, No. 04-12-00647- CV, 2013 WL 1148923, at *2 (Tex. App.—San Antonio Mar. 20, 2013, no pet.) (mem. op.); Hale v. Richey, No. 10-11-00187-CV, 2012 WL 89920, at *4 (Tex. App.—Waco Jan. 11, 2012, no pet.) (mem. op.); Max Protetch, Inc. v. Herrin, 340 S.W.3d 878, 883 (Tex. App.—Houston [14th Dist.] 2011, no pet.); Touradji v. Beach Cap. P'ship, L.P., 316 S.W.3d 15, 23 (Tex. App.—Houston [1st Dist.] 2010, no pet.); Ennis v. Loiseau, 164 S.W.3d 698, 705 (Tex. App.—Austin 2005, no pet.).

3 Following submission of this appeal, Yelp filed several notices of supplemental authority citing other courts that have held that nonresident defendants do not impliedly consent to general jurisdiction in Texas by registering to do business in Texas. See Morris v. Kan. City Ry., No. 2:24-CV-00018-JRG, 2024 WL 3347379, at *4 (E.D. Tex. July 8, 2024) (“ Mallory's conclusion of implied consent to jurisdiction does not extend to the Texas long-arm statute.”); Certain Underwriters at Lloyd's, London v. Henry Vogt Mach. Co., Inc.,

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712 S.W.3d 909, 924 (Tex. App.—Houston [14th Dist.] 2025, no pet.) (concluding that by registering to do business in Texas a nonresident company does not impliedly consent to the exercise of personal jurisdiction over them by Texas courts); Repairify, Inc. v. Opus IVS, Inc., No. 05-23-00921-CV, 2024 WL 2205663, at *1 (Tex. App.—Dallas May 16, 2024, no pet.) (mem. op.) (“[U]nlike Pennsylvania law in Mallory, none of Texas's business registration statutes—and nothing in Texas's long-arm scheme—includes any language specifically directing that complying with them would subject a business to personal jurisdiction in Texas.”). Because this ground for jurisdiction does not appear in the State's pleadings, we need not address Yelp's supplemental authority addressing the State's arguments that by registering to do business in Texas Yelp consented to general jurisdiction.

4 We note that the Texas Supreme Court held that when a plaintiff fails to establish jurisdiction through its pleadings, the plaintiff “should amend the pleading to include the necessary factual allegations, see Tex. R. Civ. P. 63, thereby allowing jurisdiction to be decided based on evidence rather than allegations, as it should be.” Kelly, 301 S.W.3d at 659. Although the State could amend its pleadings to assert the facts underlying its general jurisdiction theory, the State need not do so because the State has alleged sufficient facts to demonstrate specific personal jurisdiction over Yelp on the claims at issue.

5 In another post-submission supplemental brief, Yelp cited a Thirteenth Court of Appeals case in which our sister intermediate court held that Google was not subject to specific jurisdiction in Texas because the State did not specifically plead that the operative facts of its Deceptive Trade Practices claim arose out of or were related to Google's contacts with Texas. Google LLC v. State, No. 13-23-00114-CV, 2025 WL 52611, at *7 (Tex. App.—Corpus Christi–Edinburg Jan. 9, 2025, pet. abated) (mem. op.). This case is factually distinguishable in that, here, the State specifically pleaded that the operative facts arose out of or were related to Yelp's contacts with Texas.

6 In addition to its supplemental briefing on general jurisdiction, Yelp filed an additional supplemental brief citing two Texas Supreme Court cases in which the Court adhered to its long-established precedent that, in product-liability cases, Texas follows the “stream-of-commerce-plus” doctrine of personal jurisdiction and that “[t]argeting Texas remains the touchstone” when determining whether a nonresident defendant may be subject to personal jurisdiction in Texas. See BRP-Rotax GmbH & Co. KG v. Shaik, 716 S.W.3d 98, 108 (Tex. 2025); Hyundam Indus. Co., Ltd. v. Swacina, 716 S.W.3d 167, 174 (Tex. 2025). This is not a product liability case, but our determination that Yelp targeted Texas in appending the Consumer Notice to Texas Crisis Pregnancy Center business pages is consistent with the Texas Supreme Court's analysis in Shaik and Swacina.

End of Document © 2025 Thomson Reuters. No claim to original U.S. Government Works.

© 2025 Thomson Reuters. No claim to original U.S. Government Works. 11 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.

Zoann Willis on behalf of Richard Berlin Bar No. 24055161 zoann.willis@oag.texas.gov Envelope ID: 107275058 Filing Code Description: Letter Filing Description: 20251024 Letter of Supplemental Authority wExh 1 Status as of 10/24/2025 3:36 PM CST

Associated Case Party: State of Texas

Name BarNumber Email TimestampSubmitted Status

Rick Berlin Rick.Berlin@oag.texas.gov 10/24/2025 3:28:42 PM SENT

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Case Contacts

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