resolve matters on constitutional grounds if the matters cannot be resolved on non-constitutional grounds. See In re B.L.D., 113 S.W.3d 340, 349 (Tex.2003). Even so, we must resolve jurisdictional issues before we review issues based on the merits of the dispute. See Tex. Dept. of Parks & Wildlife v. Miranda, 133 S.W.3d 217, 228 (Tex.2004) (recognizing “fundamental precept that a court must not proceed on the merits of a case until legitimate challenges to its jurisdiction have been decided”). Google’s due process claim implicates the trial court’s jurisdiction to enter orders against Google. See Tex.R. Civ. P. 124 (requiring service, acceptance or waiver of process, or appearance before judgment can be rendered against party); PNS Stores, Inc. v. Rivera, 379 S.W.3d 267, 273 (Tex.2012) (<HOLDING>). Constitutional due process requires a party
holding that a violation of the forum defendant rule is a jurisdictional defect holding error to be fundamental when record shows jurisdictional defect holding that failure to designate the judgment or order being appealed is a jurisdictional defect holding that the district court which erred in its conclusion that there was jurisdictional defect abused its discretion in denying a plaintiffsmotion for leave to amend his complaint because the proposed amendment would not cure the jurisdictional defect holding jurisdictional defect voids judgment when defect exposes such personal jurisdictional deficiencies as to violate due process