By Chris Bankler

In GoSecure, Inc. v. CrowdStrike, Inc., Judge Andrews (Third Division) granted CrowdStrike’s special appearance and dismissed all claims for lack of personal jurisdiction.

Judge Andrews opened with a broader observation about Texas’ role in the national economy—highlighting its favorable tax policies, low-operating costs, a skilled and diverse workforce, and a large and growing customer base. That context framed the dispute: many companies operate in Texas for those reasons, but even when a company has large offices, many employees, or significant business in Texas, that alone does not subject the company to jurisdiction here for every dispute.

The case itself involved a trade-secret dispute between two California-based companies. GoSecure alleged that CrowdStrike misappropriated its technology in 2011–2012 in California. GoSecure initially sued in California, then dismissed that action and refiled in Texas.

CrowdStrike challenged jurisdiction through a special appearance.

The Court’s Rulings

General Jurisdiction

Judge Andrews began with the governing standard: general jurisdiction exists only where a defendant is “essentially at home,” typically its place of incorporation or principal place of business.

Nerve-Center Analysis

GoSecure argued that CrowdStrike’s principal place of business was in Austin. Judge Andrews rejected that argument, focusing on where the company’s leadership actually directs the business.

As Judge Andrews explained, CrowdStrike’s high-level officers “direct, control, and coordinate” its activities from California, not Texas. The Court also emphasized that key executives—including the CFO, Chief Legal Officer, and Head of Engineering—operate from the San Francisco Bay Area and direct operations from there.

GoSecure pointed to contrary indicators, including remote work and even CrowdStrike’s own AI chatbot identifying Austin as its headquarters. But Judge Andrews gave that evidence little weight, noting the absence of any showing about how the chatbot functioned or what information it relied on. On this record, Judge Andrews concluded that CrowdStrike’s nerve center is in California—not Texas.

Judge Andrews acknowledged that CrowdStrike has a significant presence in Texas, including its largest office and substantial sales. But that was not enough.

Specific Jurisdiction

Judge Andrews then turned to specific jurisdiction, which requires a substantial connection between the defendant’s Texas contacts and the operative facts of the litigation.

The Court focused on where the core events occurred: the alleged trade secrets were developed in California; the alleged misappropriation occurred in California in 2011–2012; and CrowdStrike did not establish a Texas presence until years later.

Applying Texas Supreme Court precedent, Judge Andrews explained that specific jurisdiction requires “a substantial connection between those contacts and the operative facts of the litigation.” Here, that connection was missing.

Although GoSecure pointed to CrowdStrike’s later Texas activities—sales, marketing, and possible engineering work—Judge Andrews concluded those contacts were not central to the dispute. Instead, the operative facts that will be the focus of the trial concern the alleged acquisition and early use of trade secrets in California.

Any Texas contacts were therefore peripheral, not substantially connected to the claims.

Conclusion and Takeaways

This opinion provides a straightforward application of personal-jurisdiction limits in the Business Court.

General jurisdiction remains tightly constrained. A significant Texas footprint does not make a company “at home” here. The nerve-center test continues to control. Courts will look to where leadership actually directs the business, not where the company has its largest presence.

Specific jurisdiction turns on operative facts. Later Texas activity will not support jurisdiction where the core alleged misconduct occurred elsewhere.

For companies doing business in Texas, Judge Andrews’ opinion reinforces a familiar point: substantial operations in Texas may support jurisdiction for Texas-related disputes—but not for disputes rooted somewhere else.

The opinions expressed are those of the authors and do not necessarily reflect the views of the firm, its clients, or any of its or their respective affiliates. This article is for informational purposes only and does not constitute legal advice. For more information, please contact Chris Bankler or a member of the Trial & Appellate Litigation practice.

Meet Chris

Chris Bankler focuses on the resolution of disputes for businesses and financial institutions. He counsels clients through the process of complex business litigation, including general business disputes, fraud claims, breach of fiduciary duty cases, and complex business bankruptcy litigation. He has served as litigation counsel in more than 100 cases in state and federal courts, as well as FINRA and AAA arbitrations.