If the plaintiff fails to plead facts bringing the defendant within reach of the long-arm statute (i.e., for a
tort claim, that the defendant committed tortious acts in Texas), the defendant need only prove that it does not live in Texas to negate jurisdiction.

...[M]erely pleading that Kelly and Hofstatter violated the Texas Trust Fund Act is not enough; GIC must also plead and, when challenged by the defendants, present evidence that the Officers’ relevant acts (i.e., those connected to GIC’s claims) occurred, at least in part, in Texas.”

Kelly v. General Interior Construction, Inc., No. 08-0669, 53 Tex.S.Ct..J. 247 (Tex. 2010).

The general Texas rule of "notice pleading," does not apply in special appearance litigation.

Under Rules 45 and 47, pleadings are sufficient if they give the opposing attorney fair notice of the claim involved. . . . The object and purpose of pleading is to give fair and adequate notice to the party being sued of the nature of the cause of action asserted against him so he may adequately prepare his defense.

Castleberry v. Goolsby Building Corp., 617 S.W.2d 665, 666 (Tex. 1981)(citations omitted).
 

The purpose of pleadings is to define the issues at trial. . . . A proper pleading gives fair and adequate notice of the facts relied upon, enabling the opposing party to prepare a defense.

Garvey v. Vawter, 795 S.W.2d 741, 742 (Tex. 1990)(per curiam)(holding that pleading "proximate cause" put defendant on fair notice of the issue of "foreseeability").

Further, the courts of this state have uniformly held that the rules of pleading do not require but have uniformly condemned the practice of pleading the evidence upon which a party relies to prove the allegations of his pleadings.

King v. Harris County Flood Control District, 210 S.W.2d 438, 441 (Tex.Civ.App. -- Galveston) quoted in Andrews v. Daniels, 240 S.W.2d 1018, 1021 (Tex.Civ.App. -- Austin 1951, writ dism'd)(sustaining order rejecting special exceptions).