MCI's third-party action against Marcopolo. In MCI’s appeal of the special appearance ruling, we affirmed the trial court’s decision. See Motor Coach Indus., Inc. v. Marcopolo, S.A., 2007 WL 4157241 (Tex.App.-Waco Nov.21, 2007, no pet.). MCI's eighth issue contends that, if the trial court erred by granting Marcopolo's special appearance, its severance of MCI’s third-party action against Mar-copolo would have been erroneous and the judgment should be reversed. Because we affirmed the trial court's decision on Marco-polo's special appearance, we overrule MCI's eighth issue. 2 . Two Texas Supreme Court decisions have addressed the implied preemption of state common-law tort claims by federal motor vehicle safety standards: Hyundai Motor Co. v. Alvarado, 974 S.W.2d 1, 13 (Tex.1998) (<HOLDING>); and Great Dane Trailers, Inc. v. Estate of
holding that a state common law claim seeking to require automobile manufacturers to install airbags would frustrate the purposes of the federal safety standard regulations adopted under the federal motor vehicle safety act which did not require manufacturers to do so and therefore was preempted by conflict holding that the safety act and fmvss 108 did not impliedly preempt commonlaw conspicuity tort based on inadequate lighting and reflectors on truck trailer holding that the coast guards decision not to regulate propeller guards did not impliedly preempt petitioners tort claims holding that the safety act and fmvss 208 did not expressly or impliedly preempt a tort claim based on the manufacturers failure to install lap belts holding that claims were nothing more than a backdoor attempt to attack once again the manufacturers exercise of one of the restraint options under fmvss 208  it therefore frustrates the purpose and objective of the federal regulation and invokes implied preemption under the holding in geier 