1. What is the practical implication of this decision? Does it mean that Clemens cannot bring suit for defamation in any court?
2. If McNamee had claimed that he injected Clemens with the drugs while in Texas, would that change the court’s analysis? How?

McNamee had been an athletic trainer who had worked for both the Toronto Blue Jays and New York Yankees baseball teams and after authorities convinced McNamee that they had sufficient evidence to convict him for injecting athletes with anabolic steroids, McNamee agreed to cooperate with investigators in exchange for immunity from prosecution. During an interview with investigators, McNamee admitted that he had administered the drugs to star pitcher Roger Clemens both in Toronto and New York. McNamee repeated these allegations to Major League Baseball investigators and to a reporter during an interview with Sports Illustrated. In 2008, Clemens, a resident of Texas, filed suit against McNamee for defamation in Texas. The trial court dismissed the suit due to lack of personal jurisdiction because the focal point of McNamee’s statements was not in Texas. Clemens appealed.