Smith, 307 S.W.3d 762, 776 (Tex.2010). And it has repeatedly “rejected attempts to blur the distinction between these two claims,” much less to eliminate that distinction. See State v. Shumake, 199 S.W.3d 279, 284 (Tex.2006); Keetch v. Kroger Co., 845 S.W.2d 262, 264 (Tex.1992) (declining “to eliminate all distinction between premises conditions and negligent activities”). “Recovery on a negligent activity theory requires that the person have been injured by or as a contemporaneous result of the activity itself rather than by a condition created by the activity.” Timberwalk, 972 S.W.2d at 753. A premises owner performing an activity on property it controls has a duty to use ordinary care so that its activity does not proximately cause foreseeable injury. See Del Lago, 307 S.W.3d at 777 (<HOLDING>); Moritz, 257 S.W.3d at 214; West v. SMG, 318
holding that premises owner had duty to use degree of care in performing activities that owner of ordinary prudence would use under same or similar circumstances holding that negligence in premises defect context generally means failure to use ordinary care to reduce or eliminate unreasonable risk of harm created by premises condition about which owner or occupier of land is aware holding that trustees have a duty to exercise the same judgment and prudence that a careful owner would exercise in the sale of his own property holding employers to an ordinary prudence standard of care holding that a business owner has a duty to use reasonable care to maintain premises in a reasonably safe condition for patrons