citation_id,filing_id,case_name,citation,court,year,proposition,cited_by 252,28,In re Cordish Co.,"617 S.W.3d 909, 913, 915",Tex. App.—Houston [14th Dist.],2021,"To withstand an objection to RTP designation, the movant must satisfy the notice pleading standard with allegations regarding responsibility, including notice of alleged duty breached and sufficient allegations of causation, so parties can ascertain the nature and basic issues of the controversy",Pohl 253,28,In re Smith,"366 S.W.3d 282, 286",Tex. App.—Dallas,2012,Responsibility for 'harm' in the RTP context is not the same as responsibility for 'damages',Pohl 254,28,City Nat'l Bank of Sulphur Springs v. Smith,"No. 06-15-00013-CV, 2016 WL 2586607, at *7–9",Tex. App.—Texarkana,2016,"'Harm' is synonymous with 'injury' and has a meaning distinct from 'damages'; to be a responsible third party, one must contribute to the harm for which damages are sought, not to the damages themselves",Pohl 255,28,DLA Piper LLP (US) v. Linegar,"539 S.W.3d 512, 517",Tex. App.—Eastland,2017,"A potential RTP must be responsible for the harm underlying the pled cause of action, not merely plausibly connected with damages",Pohl 256,28,Burns v. Rochon,"190 S.W.3d 263, 271",Tex. App.—Houston [1st Dist.],2006,The injury or harm that gives rise to a conversion claim is a defendant's 'unlawful taking' of the plaintiff's property,Pohl 257,28,Pemex Exploracion y Produccion v. BASF Corp.,"CIV.A. H-10-1997, 2013 WL 5514944, at *31",S.D. Tex.,2013,"Each wrongful possession of converted property is a separate conversion; when property is converted and transferred, each possession is a new conversion (applying Texas law)",Pohl 258,28,Sw. Energy Prod. Co. v. Berry-Helfand,"491 S.W.3d 699, 721–22",Tex. Supreme Court,2016,The harm or injury giving rise to a trade-secret misappropriation claim is the unauthorized use of the trade secrets; 'use of the trade secret means commercial use by which the offending party seeks to profit from the use of the secret',Pohl 259,28,"Ambrosio v. Carter's Shooting Ctr., Inc.","20 S.W.3d 262, 266",Tex. App.—Houston [14th Dist.],2000,Merely furnishing a condition that made the injury possible is not proximate cause,Pohl 260,28,In re Dawson,"550 S.W.3d 625, 630",Tex. Supreme Court,2018,"A party's failure to provide name, address, and telephone number of potential RTPs in disclosure responses can show they did not satisfy their obligations under Rule 194.2(l) and section 33.004(d)",Pohl