The sale of licensed software and digital content to Texas users by a Utah company primarily through Internet downloads established substantial nexus with Texas for sales and use tax purposes. Nexus was created because the seller retained title to tangible personal property – the software – that was physically present and generating license revenue in Texas. The license agreements granted the customer a license to use the seller’s products, restricted the use of the products by third parties, and explicitly provided that the seller retained all rights in, title to, and ownership of the licensed products. The seller did not challenge the characterization of its software products as tangible personal property. As a result, the seller retained property rights in tangible personal property that was present and generating recurring revenue in Texas. This reservation of property rights overrode the seller’s claim that it lacked the requisite physical presence to create sales tax nexus in Texas. Visits by several of the seller’s employees at two conferences held in Texas during the audit period did not establish nexus because the employees did not solicit orders or engage in any sales activities and were present at the conferences only for learning purposes. (Decision, Hearing No. 108,626, Texas Comptroller of Public Accounts, September 19, 2014, released November 2014)