Ladrillera Mecanizada, S.A. De C v. v. Gugtre, S.A. De C.V.

Fourth Court of Appeals San Antonio, Texas MEMORANDUM OPINION No. 04-25-00615-CV LADRILLERA MECANIZADA, S.A. DE C.V., Appellant v. GUGTRE, S.A. DE C.V., Appellee From the 293rd Judicial District Court, Maverick County, Texas Trial Court No. 25-06-44660-MCV Honorable Maribel Flores, Judge Presiding Opinion by: Adrian A. Spears II, Justice Sitting: Rebeca C. Martinez, Chief Justice Lori I. Valenzuela, Justice Adrian A. Spears II, Justice Delivered and Filed: September 23, 2026 AFFIRMED Ladrillera Mecanizada, S.A. de C.V. (“Ladrillera”) appeals the trial court’s order denying its special appearance in an original action brought under the Uniform Foreign-Country Money Judgments Recognition Act (“UFCMJRA”). We affirm. BACKGROUND After a Mexican court rendered two money judgments in favor of Gugtre, S.A. de C.V. (“Gugtre”) and against Ladrillera, Gugtre filed an original petition in the 293rd District Court in  04-25-00615-CV Maverick County, Texas, seeking recognition of the foreign judgments for purposes of enforcement. Gugtre’s petition alleged that Ladrillera “engages in business in Texas, but has failed to designate or maintain a resident agent for service of process.” The petition further alleged that Ladrillera “markets and sells its manufactured products in Texas, recruits Texas residents for employment, contracts with Claymex Brick and Tile, Inc. to do business in Texas, publicly announces having four offices in Texas, submits applications with the Texas Department of Insurance, and has accounts receivable in Texas.” In response, Ladrillera filed a special appearance challenging the trial court’s personal jurisdiction over it. Attached to Ladrillera’s special appearance was the declaration of its chief executive officer declaring, under penalty of perjury, that Ladrillera was not organized under the laws of the State of Texas, is not a resident of Texas, is not registered to do business in Texas, and does not maintain offices or a place of business in Texas. The declaration further affirmed that Ladrillera “does not maintain any employees, servants, or agents within the State of Texas,” “does not recruit Texas residents for employment,” “does not directly market its products in Texas,” and “does not contract with Claymex Brick and Tile, Inc. to do business in Texas.” According to the declaration, “Claymex purchases products from Ladrillera in Mexico,” “takes delivery of those products in Mexico,” and then “imports the products into the United States.”. The chief executive officer’s declaration explained that “Ladrillera’s sole source of receivables in Texas is from its sale of products to Claymex, which are purchased by and delivered to Claymex in Mexico and imported by Claymex into the United States.” “Ladrillera does not maintain accounts to collect receivables from any other businesses in Texas.” The declaration stated that “Ladrillera submitted a single application to the Texas Department of Insurance in 2013,” which had “nothing to do with the claims at issue in this case.” The chief executive officer’s declaration stated that the litigation -2-  04-25-00615-CV between Ladrillera and Gugtre concerned “a dispute over payment of rent for a commercial property located in Mexico” and that “the judgments at issue in [Gugtre]’s [p]etition concern that same dispute over payment of rent for the commercial property located in Mexico.” Gugtre then filed a written response to Ladrillera’s special appearance and attached evidence. Gugtre’s response asserted the trial court had both personal and quasi in rem jurisdiction over Ladrillera. Gugtre attached a declaration from Isaac Budnik Villarreal, which affirmed that the homepage of Ladrillera’s website stated on February 6, 2025 that Ladrillera had “4 offices in Texas” and showed four “Store Locations” in Texas. Villarreal’s declaration further stated that on September 9, 2025, the website was altered and “the logos for the four Texas offices displayed on the ‘Store Locations’ page had been changed to reflect Ladrillera’s affiliate, Claymex Brick & Tile Inc.” The declaration included screenshots taken of Ladrillera’s website on those dates. The trial court denied Ladrillera’s special appearance, stating in its order that it had considered the special appearance and the evidence supporting the special appearance, the response and the evidence supporting the response, and the arguments of counsel. The trial court’s order did not specify the basis for its ruling. Findings of fact and conclusions of law were not requested or filed. Ladrillera then appealed the trial court’s interlocutory order. See TEX. CIV. PRAC. & REM. CODE § 51.014(a)(7) (authorizing an interlocutory order that grants or denies a defendant’s special appearance). SPECIAL APPEARANCE AND THE UFCMJRA The threshold issue presented in this appeal is whether Ladrillera was entitled to file a special appearance under the UFCMJRA. In Texas, the recognition of foreign judgments is governed by the UFCMJRA, which is codified in Chapter 36A of the Texas Civil Practice and Remedies Code. See TEX. CIV. PRAC. & REM. CODE §§ 36A.001-.011. -3-  04-25-00615-CV By recognizing a foreign-country judgment, a Texas court accepts the judgment rendered by a court in a foreign country. Dynaresource de Mexico S.A. de C.V. v. Goldgroup Res. Inc., 667 S.W.3d 918, 925 (Tex. App.—Dallas 2023, no pet.). Two purposes exist for the recognition of foreign judgments: (1) to domesticate a judgment for purposes of enforcement, and (2) to attain preclusive effect of that judgment. Id. at 926. “Because the forum court cannot enforce the foreign- country judgment until it has determined that the judgment will be given effect, recognition is a prerequisite to enforcement of the foreign-country judgment.” Id. at 925. In 2017, the Legislature dramatically altered the procedure for recognizing foreign country judgments in Texas by repealing the former recognition statute and enacting the current version. See Acts 2017, 85th Leg., ch. 390 (S.B. 944), § 2, effective June 1, 2017 (repealing Act of 1989, 71st Leg., ch. 402 § 5, 1989 Tex. Sess. Law Serv. 402). Under the former recognition statute, a judgment creditor seeking recognition of a foreign-country judgment filed a final, authenticated copy of the foreign-country judgment in the office of the clerk of the court or in any court of competent jurisdiction and served the judgment debtor with notice of the filing. See Hernandez v. Seventh Day Adventist Corp., 54 S.W.3d 335, 337 (Tex. App.—San Antonio 2001, no pet.). The former statute placed the burden on the judgment debtor to file a contest to the recognition of a foreign judgment. See id. The former statute did not require a Texas court to make a determination about whether a foreign-country judgment should be recognized. See id. The mere filing of the foreign-country judgment in the Texas court effectively served as both the judgment creditor’s original petition and the final judgment. See id. By contrast, under the current recognition statute, a judgment creditor seeking recognition of a foreign-country judgment must either commence an original action or assert the claim by counterclaim, cross-claim, or affirmative defense. See TEX. CIV. PRAC. & REM. CODE § 36A.006. -4-  04-25-00615-CV The trial court then renders a separate recognition judgment. See id. §§ 36A.003-.007. Unlike its predecessor, the current statute eliminates the automatic recognition process and instead requires the court to determine whether the foreign-country judgment is entitled to recognition in Texas. See id. §§ 36A.003-.007; Lancaster v. WestCorp Sols., Ltd., 673 S.W.3d 57, 63 (Tex. App.— Corpus Christi-Edinburg 2023, no pet.). Thus, under the current statute, the issue of recognition must always be presented and resolved in a judicial proceeding. See Lancaster, 673 S.W.3d at 63. It necessarily follows that the parties must comply with all applicable state procedural rules governing such proceedings. Here, Ladrillera argues that a plaintiff filing a suit under the UFCMJRA is subject to the same personal jurisdiction requirements as other plaintiffs in other Texas civil suits and, therefore, it is entitled to the relief provided in Texas Rule of Civil Procedure 120a. Rule 120a provides that “a special appearance may be made by any party . . . for the purpose of objecting to the jurisdiction of the court over the person or property of the defendant on the ground that [the defendant] is not amenable to process issued by the courts of this State.” TEX. R. CIV. P. 120(a)(1). Ladrillera urges us to follow the precedent set in Dynaresource, 667 S.W.3d at 927, a case in which the Dallas Court of Appeals “expressly conclude[d] that the Texas Rules of Civil Procedure apply to a UFCMJRA recognition suit, including Rule 120a, with attendant application of Texas jurisprudence to those rules.” Although we reach the same result, we do not adopt Dynaresource’s reasoning. Dynaresource’s reasoning relied heavily on the comments promulgated by the National Conference of Commissioners on Uniform State Laws (“NCCUSL”), which were not adopted by the Texas Legislature. 1 Instead, our conclusion rests on the text of the UFCMJRA itself and normal rules of statutory construction. The Texas Supreme Court has stated that we are allowed to construe comments accompanying a model law, but we 1 must “remain mindful” that the “comments were not adopted by our Legislature and cannot alter the plain meaning of -5-  04-25-00615-CV “When construing a statute, we begin with its language.” State v. Shumake, 199 S.W.3d 279, 284 (Tex. 2006). Our primary objective is to determine and give effect to “the Legislature’s intent which, when possible, we discern from the plain meaning of the words chosen.” Id.; see City of San Antonio v. City of Boerne, 111 S.W.3d 22, 25 (Tex. 2003); Fitzgerald v. Advanced Spine Fixation Sys., Inc., 996 S.W.2d 864, 865 (Tex. 1999); Lancaster, 673 S.W.3d at 62. If the statute is clear and unambiguous, we must apply its words according to their common meaning without resort to rules of construction or extrinsic aids. Fitzgerald, 996 S.W.2d at 865-66. Further, “whether or not the statute is considered ambiguous on its face,” we “may consider among other matters” the objective of the law, its history, and the consequences of a particular construction. TEX. GOV’T CODE § 311.023(1), (3), (5); see Union Bankers Ins. Co. v. Shelton, 889 S.W.2d 278, 280 (Tex. 1994) (“When determining legislative intent, the courts may look to the language of the statute, legislative history, the nature and object to be obtained, and the consequences that would follow from alternate constructions.”). Statutory construction is a question of law that we review de novo. Shumake, 199 S.W.3d at 284; City of San Antonio, 111 S.W.3d at 25. Section 36A.006 provides that “[i]f recognition of a foreign-country judgment is sought as an original matter, the issue of recognition may be raised by filing an action seeking recognition of the foreign-country judgment.” TEX. CIV. PRAC. & REM. CODE § 36A.006. By characterizing the proceeding as an “original matter” and requiring a party to file an “action,” the Legislature employed terms that have well established meanings in Texas practice. Put simply, an original action is commenced and governed by the Texas Rules of Civil Procedure. Nothing in the UFCMJRA indicates an intent to depart from those ordinary procedural rules. Accordingly, the the words enacted, which are ‘the truest manifestation of what legislators intended.’” Janvey v. Golf Channel, Inc., 487 S.W.3d 560, 573 (Tex. 2016) (quoting Alex Sheshunoff Mgmt. Servs., L.P. v. Johnson, 209 S.W.3d 644, 651 (Tex. 2006)). -6-  04-25-00615-CV statute’s plain language is sufficient to resolve the issue before us. Indeed, the statute’s legislative history confirms this reading. The Legislature’s intent in enacting the current statute was to protect Texans’ individual due process rights with respect to foreign court systems. See Tex. S. Rsch. Ctr., Bill Analysis, S.B. 944, 85th Leg., R.S. (6/22/2017) (stating that “not all foreign court systems honor basic individual and system due process protections recognized by U.S. state courts [like] the Texas state court system” and that the “provisions of S.B. 944 ensure that Texans’ individual due process rights continue to be recognized by foreign judicial systems before those foreign judgments are enforced by Texas courts”). By adopting the 2017 Uniform Foreign-Country Money Judgments Recognition Act, the Legislature overhauled the former recognition statute and expanded the grounds for recognition, thus ensuring that Texas courts scrutinize foreign country judgments before recognizing and enforcing them. Compare Act of 1989, 71st Leg., R.S., ch. 402 § 5, 1989 Tex. Sess. Law Serv. 402 (former version of act), with Act 2017, 85th Leg., R.S., ch. 390, §§ 1-4, 2017 Tex. Sess. Law Serv. 390 (codified at TEX. CIV. PRAC. & REM. CODE §§ 36A.001-.011). To ensure due process, the current UFCMJRA requires a foreign judgment creditor to file either an original proceeding in Texas or, if an action is already pending in Texas, a counterclaim or cross-claim for recognition. See TEX. CIV. PRAC. & REM. CODE § 36A.006. The nature of the modifications made to the recognition procedure by the Legislature make it evident that the judgment creditor must abide by Texas rules currently in existence, including Texas Rule of Civil Procedure 120a. It would be nonsensical to conclude that the Legislature, in making the modifications to the statute, intended Texas courts to scrutinize whether a foreign judicial system provided adequate due process while simultaneously allowing a judgment creditor to disregard the procedural due process safeguards that Texas law requires. The current version of the UFCMJRA -7-  04-25-00615-CV is designed to protect litigants from foreign judgments obtained through procedures that fail to satisfy due process. That same concern necessarily extends to the recognition proceeding itself. Moreover, nothing in the current statute suggests the Legislature intended to exempt a judgment creditor from complying with the Texas procedural rules that safeguard due process once the creditor seeks relief in a Texas court. We therefore hold that when a judgment creditor seeks recognition by filing an original action under Chapter 36A, it must comply with the Texas Rules of Civil Procedure applicable to original lawsuits. Likewise, when recognition is sought by counterclaim, crossclaim, or affirmative defense in a pending action, the judgment creditor must comply with the procedural rules governing those pleadings. In either circumstance, the judgment creditor must satisfy the same due process requirements that the UFCMJRA was enacted to protect. We note that Gugtre argues that a special appearance pursuant to Texas Rule of Civil Procedure 120a is wholly inapplicable to a suit filed under the UFCMJRA. Gugtre urges us to follow Beluga Chartering B.V. v. Timber S.A., 294 S.W.3d 300, 305 (Tex. App.—Houston [14th Dist.] 2009, no pet.), and Haaksman v. Diamond Offshore (Bermuda), Ltd., 260 S.W.3d 476 (Tex. App.—Houston [14th Dist.] 2008, pet. denied). Beluga and Haaksman examined the former recognition statute and held that it did not require personal jurisdiction over a judgment debtor in Texas as a prerequisite for enforcing a foreign country judgment in Texas. See Beluga, 294 S.W.3d at 305; Haaksman, 260 S.W.3d at 479-80. However, having determined that the former recognition statute was modified to protect litigants from foreign judgments obtained through procedures that fail to satisfy due process, we decline to follow Haaksman and Beluga. See Dynaresource, 667 S.W.3d at 928 (declining to follow Haaksman and Beluga when analyzing suit for recognition filed under Chapter 36A). -8-  04-25-00615-CV REVIEW OF DENIAL OF SPECIAL APPEARANCE Having determined that Texas Rule of Civil Procedure 120a and special appearance law is applicable to a suit under the UFCMJRA, we must next determine if the trial court properly denied Ladrillera’s special appearance. A. Standard of Review Whether a trial court has personal jurisdiction over a nonresident defendant is a question of law, which we review de novo. BMC Software Belg., N.V. v. Marchand, 83 S.W.3d 789, 794 (Tex. 2002); Maynard v. Lucero, No. 04-23-00665-CV, 2025 WL 984586, at *3 (Tex. App.—San Antonio Apr. 2, 2025, pet. denied). In deciding the jurisdictional issue, a trial court frequently resolves questions of fact. BMC Software, 83 S.W.3d at 794; Maynard, 2025 WL 984586, at *3. When, as here, the trial court does not issue findings of fact and conclusions of law with its special appearance ruling, we imply all facts necessary to support the judgment provided those facts are supported by the evidence. M & F Worldwide Corp. v. Pepsi-Cola Metro. Bottling Co., 512 S.W.3d 878, 885 (Tex. 2017); BMC Software, 83 S.W.3d at 795. B. Special Appearance Procedures The plaintiff has “the initial burden to plead sufficient allegations to bring the nonresident defendant within the reach of Texas’s long-arm statute.” Kelly v. Gen. Interior Constr., Inc., 301 S.W.3d 653, 658 (Tex. 2010). Once the plaintiff sufficiently pleads these jurisdictional allegations, the burden then shifts to the defendant to negate all the alleged bases of personal jurisdiction. Id. “The defendant can negate jurisdiction on either a factual or legal basis.” Id. at 659. “Factually, the defendant can present evidence that it has no contacts with Texas, effectively disproving the plaintiff’s allegations.” Id. “The plaintiff can then respond with its own evidence that affirms its allegations, and it risks dismissal of its lawsuit if it cannot present the trial court with evidence -9-  04-25-00615-CV establishing personal jurisdiction.” Id. “Legally, the defendant can show that even if the plaintiff’s alleged facts are true, the evidence is legally insufficient to establish jurisdiction; the defendant’s contacts with Texas fall short of purposeful availment; for specific jurisdiction, that the claims do not arise from the contacts; or that traditional notions of fair play and substantial justice are offended by the exercise of jurisdiction.” Id. C. Specific and General Jurisdiction “Texas courts may exercise personal jurisdiction over a nonresident defendant when (1) our long-arm statute authorizes it and (2) doing so comports with federal and state constitutional due process guarantees.” Goldstein v. Sabatino, 690 S.W.3d 287, 294 (Tex. 2024). 2 The Texas long-arm statute permits a trial court to exercise personal jurisdiction over a defendant who “does business in this state.” LG Chem Am., Inc. v. Morgan, 670 S.W.3d 341, 346 (Tex. 2023) (quoting TEX. CIV. PRAC. & REM. CODE § 17.042). “[B]ecause Texas’s long-arm statute extends personal jurisdiction as far as the federal constitutional requirements allow, the ‘federal due process requirements shape the contours of Texas courts’ jurisdictional reach.’” Goldstein, 690 S.W.3d at 294 (quoting Searcy v. Parex Res., Inc., 496 S.W.3d 58, 66 (Tex. 2016)). 2 The parties focus on the distinction between in personam, in rem, and quasi in rem jurisdiction. That distinction, however, does not alter the governing constitutional analysis. Texas courts apply the same minimum-contacts analysis to in personam, in rem, and quasi in rem proceedings alike. As the Texas Supreme Court has explained, the mere presence of property in Texas does not, standing alone, establish the minimum contacts necessary to support quasi in rem jurisdiction. See Dawson-Austin v. Austin, 968 S.W.2d 319, 327 (Tex. 1998) (explaining that any property in Texas that is part of the marital estate in this case cannot, by itself, supply the requisite minimum contacts for the trial court to exercise personal jurisdiction over the nonresident defendant or quasi in rem jurisdiction to adjudicate the parties’ property interests); see also Mason v. Mason, 321 S.W.3d 178, 183, 186 (Tex. App.—Houston [1st Dist.] 2010, no pet.) (relying on Dawson-Austin and holding that the trial court had no personal jurisdiction over nonresident defendant or the subject property in Texas where the record did not show that the nonresident defendant had purposefully availed herself “of the benefits and protections of the laws of this state in order to protect her interest in the marital estate”). Thus, before a Texas court may exercise jurisdiction, Gugtre, as plaintiff, had to establish sufficient contacts connecting Ladrillera, the property, and this litigation to Texas. - 10 -  04-25-00615-CV A state’s exercise of personal jurisdiction comports with federal due process if (1) the nonresident defendant has “minimum contacts” with the state, and (2) the exercise of jurisdiction comports with traditional notions of fair play and substantial justice. Int’l Shoe Co. v. Washington, 326 U.S. 310, 316 (1945); M & F Worldwide Corp., 512 S.W.3d at 885. A nonresident defendant’s minimum contacts may give rise to either specific jurisdiction or general jurisdiction. Guardian Royal Exch. Assur., Ltd. v. English China Clays, P.L.C., 815 S.W.2d 223, 227 (Tex. 1991). Specific jurisdiction exists when (1) the defendant has made minimum contacts with Texas by purposefully availing itself of the privilege of conducting activities in the state and (2) the defendant’s potential liability arose from or is related to those contacts. In re Christianson Air Conditioning & Plumbing, LLC, 639 S.W.3d 671, 679 (Tex. 2022). The defendant’s contacts “must be purposeful rather than random, fortuitous, or attenuated.” Id. (quoting Moncrief Oil Int’l, Inc. v. OAO Gazprom, 414 S.W.3d 142, 151 (Tex. 2013)). A “minimum-contacts analysis focuses solely on the actions and reasonable expectations of the defendant.” Michiana Easy Livin’ Country, Inc. v. Holten, 168 S.W.3d 777, 790 (Tex. 2005). General jurisdiction exists “when a defendant’s contacts in a forum are continuous and systematic so that the forum may exercise personal jurisdiction over the defendant even if the cause of action did not arise from or relate to activities conducted within the forum state.” BMC Software Belgium, 83 S.W.3d at 796. “When general jurisdiction is asserted, the minimum contacts analysis is more demanding and requires a showing of substantial activities in the forum state.” Guardian Royal, 815 S.W.2d at 228 (emphasis added). “General jurisdiction requires that a defendant be ‘essentially at home’ in the forum state.” In re Christianson Air Conditioning, 639 S.W.3d at 679 (quoting Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915, 919 (2011)). The record reflects that Ladrillera regularly sells and distributes clay products in Texas and maintains property and assets - 11 -  04-25-00615-CV in Texas. Although Ladrillera disputes the evidence, the record also contains some evidence that it maintained four offices in Texas. Because the trial court made no findings of fact, we presume that the trial court resolved all disputed fact issues in support of its judgment. See M & F Worldwide Corp., 512 S.W.3d at 885. Accordingly, we hold the trial court could have relied on the evidence of Ladrillera’s Texas offices, together with its regular sales and distribution activities in Texas, to conclude that Ladrillera has continuous and systematic contacts with Texas. See BMC Software Belgium, 83 S.W.3d at 795. Thus, we hold general jurisdiction supports the trial court’s personal jurisdiction over Ladrillera. Moreover, even if the evidence had not supported general jurisdiction, we conclude that the evidence supports a conclusion by the trial court that specific jurisdiction exists. “When specific jurisdiction is asserted, the minimum contacts analysis focuses on the relationship among the defendant, the forum, and the litigation.” Guardian Royal, 815 S.W.2d at 228. Under a specific jurisdiction analysis, we first determine whether Ladrillera purposefully established minimum contacts with Texas; that is, whether there exists a substantial connection between Ladrillera, Texas, and the operative facts arising from conduct purposefully directed toward this state. 1. Purposeful Availment We examine the evidence on a claim-by-claim basis. In this case, Ladrillera is a Mexican manufacturer of clay products, including bricks, tiles, and flooring, which it distributes domestically in Mexico and internationally, with significant volumes exported to Texas consumers. Under the “stream of commerce” doctrine, a “seller’s awareness that the stream of commerce may or will sweep the product into the forum State does not [necessarily] convert the mere act of placing the product in the stream into an act purposefully directed toward the forum State.” Luciano v. SprayFoamPolymers.com, LLC, 625 S.W.3d 1, 9-10 (Tex. 2021) (citation - 12 -  04-25-00615-CV omitted). There must be more than that to support purposeful availment: “Texas courts require ‘additional conduct’ evincing ‘an intent or purpose to serve the market in the forum State,’ whether directly or indirectly.” Id. at 10 (quoting TV Azteca v. Ruiz, 490 S.W.3d 29, 46 (Tex. 2016)). “Thus, while ‘a nonresident need not have offices or employees’” in Texas to purposefully avail itself of the state, directing “marketing efforts to [Texas] in the hope of soliciting sales” may make the nonresident subject to Texas jurisdiction in suits “‘arising from that business.’” Id. (quoting Michiana, 168 S.W.3d at 785). In this case, the record reflects that Ladrillera regularly sells and distributes clay products in Texas. More importantly, Ladrillera’s products that bear its logo are physically present in Texas, and the evidence shows that Ladrillera maintains accounts receivable in Texas through its affiliate and distributor, Claymex. Ladrillera’s Chief Executive Officer acknowledged these Texas contacts in his sworn declaration, admitting that “Ladrillera’s sole source of receivables in Texas is from its sale of products to Claymex” and that “Ladrillera does not maintain accounts to collect receivables from any other businesses in Texas.” The record further shows that Ladrillera applied to the Texas Department of Insurance in 2020 and 2021 in connection with products marketed in Texas. Additionally, the evidence shows that Ladrillera owns property in Texas in the form of bricks, tiles, and other clay building materials manufactured by Ladrillera and located within Texas. Finally, there is evidence of four offices located in Texas. Accordingly, we hold that Ladrillera’s contacts with Texas were not random, isolated, or fortuitous. Rather, they demonstrate that Ladrillera purposefully directed its conduct toward Texas and purposefully availed itself of the privilege of conducting activities within Texas. Ladrillera argues that Gugtre failed to include specific allegations regarding Ladrillera’s Texas assets in its original petition, asserting that this court may not consider the additional - 13 -  04-25-00615-CV allegations contained in Gugtre’s response. We disagree. We have consistently held that when considering if a plaintiff has met its burden to allege facts supporting personal jurisdiction, we review not only the plaintiff’s petition but also its response. See Little & Gorgeous, Inc. v. Wild Tribe Screen Prints, LLC, 717 S.W.3d 36, 44 (Tex. App.—San Antonio 2025, pet. denied) (explaining that in reviewing whether plaintiff met its initial burden, we “not only review [the plaintiff]’s petition but also, as relevant here, [the plaintiff]’s response to” the defendant’s special appearance, the plaintiff’s affidavit, and “the results of the discovery process”); Cirrus Design Corp. v. Berra, 633 S.W.3d 640, 649-50 (Tex. App.—San Antonio 2021, no pet.) (rejecting defendant’s argument that we could not “consider the press release because it is evidence of a Texas activity that occurred after [the plaintiff] filed her petition” by explaining that in a specific jurisdiction analysis, we many consider such evidence occurring after the filing of a lawsuit because “it provides evidence of a continuum of activities demonstrating [the defendant’s] ongoing marketing in Texas”); see also Kelly v. Gen. Interior Constr., Inc., 301 S.W.3d 653, 658 n.4 (Tex. 2010) (explaining that while the plaintiff’s petition is “essential to frame the jurisdictional dispute,” it “is not dispositive” because “Rule 120a requires a special appearance to be made by sworn motion” and “also requires the trial court to ‘determine the special appearance on the basis of the pleadings, any stipulations made by and between the parties, such affidavits and attachments as may be filed by the parties, the results of discovery processes, and any oral testimony’”) (quoting TEX. R. CIV. P. 120a). 2. Substantial Connection Under Texas law, specific jurisdiction requires not only purposeful contacts with the forum but also “a substantial connection between those contacts and the operative facts of the litigation.” Moki Mac River Expeditions v. Drugg, 221 S.W.3d 569, 585 (Tex. 2007); see Guardian Royal, - 14 -  04-25-00615-CV 815 S.W.2d at 229-33. This case is brought under section 36A.006 of the Texas Civil Practice and Remedies Code to recognize a foreign-country judgment. See TEX. CIV. PRAC. & REM. CODE § 36A.006. Once a trial court in a proceeding under section 36A.006 determines that the foreign- country judgment is entitled to recognition, the judgment is conclusive between the parties to the same extent as a judgment of a sister state entitled to full faith and credit in Texas would be conclusive, and it is enforceable in the same manner and to the same extent as a judgment rendered in Texas. See id. § 36A.007. Accordingly, this proceeding does not concern the merits or underlying facts of the foreign dispute. Rather, it concerns the recognition and potential enforcement of the foreign judgment against Ladrillera to obtain its property and assets located in Texas to satisfy the judgment. The suit may either arise out of or relate to the defendant’s forum contacts and still support jurisdiction. The contacts need not have caused the suit; “some relationships will support jurisdiction without a causal showing.” Luciano, 625 S.W.3d at 15 (quoting Ford Motor Co. v. Montana Eighth Jud. Dist. Ct., 592 U.S. 351, 362 (2021)). Accordingly, the record establishes that Ladrillera’s contacts with Texas are directly related to this recognition proceeding because the action seeks to recognize a foreign-country judgment and thereafter enforce the judgment against Ladrillera’s Texas property and assets. The requisite nexus therefore exists among Ladrillera, Texas, the property, and the litigation, satisfying the constitutional requirements for the exercise of specific jurisdiction. 3. Fair Play and Substantial Justice Once minimum contacts have been established, we must still consider whether exercising jurisdiction over Ladrillera would run afoul of “traditional notions of fair play and substantial justice.” Luciano, 625 S.W.3d at 18. “Only in rare cases, however, will the exercise of jurisdiction not comport with fair play and substantial justice when the nonresident defendant has purposefully - 15 -  04-25-00615-CV established minimum contacts with the forum state.” Id. (quoting Guardian Royal, 815 S.W.2d at 231). In making this determination, the following factors, when appropriate, should be considered: (1) the burden on the defendant; (2) the interests of the forum state in adjudicating the dispute; (3) the plaintiff’s interest in obtaining convenient and effective relief; (4) the interstate judicial system’s interest in obtaining the most efficient resolution of controversies; and (5) the shared interest of the several states in furthering fundamental substantive social policies. Id. at 18-19. The Legislature’s 2017 revisions underscore that recognition is no longer a ministerial act but a judicial proceeding requiring a Texas court to determine whether a foreign-country judgment should be recognized before it may be enforced. Requiring a judgment creditor to obtain recognition in a court proceeding before enforcing against the judgment debtor or against Texas property promotes (1) the orderly administration of justice, (2) protects the due process rights of the judgment debtor, and (3) ensures the judgment debtor, before any enforcement may occur, has an opportunity to participate in the proceeding determining whether the foreign-country judgment satisfies the Act’s mandatory and discretionary grounds for nonrecognition. Thus, the proceeding ensures that the judgment debtor is afforded due process before foreign judgment is given effect in Texas. Finally, Texas has a strong policy interest in recognizing and enforcing valid foreign- country judgments in accordance with the Act. Under these circumstances, we conclude that exercising specific jurisdiction over Ladrillera in this recognition proceeding does not offend traditional notions of fair play and substantial justice. CONCLUSION We hold that the trial court did not err by denying the special appearance. Ladrillera purposefully availed itself of the privilege of conducting activities in Texas and those activities are sufficiently related to the facts of this case. Accordingly, the exercise of personal jurisdiction over - 16 -  04-25-00615-CV Ladrillera comports with constitutional due process guarantees. We therefore affirm the trial court’s order denying Ladrillera’s special appearance. Adrian A. Spears II, Justice - 17 -