The History of E-Service Cases
Last updated January 31, 2017
Electronic service of process has changed the landscape of the civil process serving industry by providing new methods to serve legal documents to individuals, who in most cases have been otherwise elusive. In the table below, we've researched and included instances in which electronic service of process was used.
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E-Service Timeline and Cases
| Date | Court Location | State | Case | Type of E-Service | Description | Link |
|---|---|---|---|---|---|---|
| 1980 | U.S. District Court for the Southern District of New York | NY | New England Merchants National Bank v. Iran Power Generation & Transmissions Co | Telex Message | Essentially, old-school fax/text messaging machine - approved by court | |
| August 15, 1996 | Massachusetts Federal District Court C | MA | Greebel v FTP Software Inc. | Online PressRelease | FTP next contends that Greebel's press release on Business Wire failed to satisfy the PSLRA's publication requirement. As such, it seems clear that the mere fact that Business Wire arrives at a print publication via an electronic signal, rather that in the manner of a traditional wire service, does not disqualify it as a "wire service" within the meaning of the statute. | Details |
| 2000 | United States Bankruptcy Court for the Northern District of Georgia | GA | Broadfoot v. Diaz | The dispute centered around the trustee of International Telemedia Associates, Inc. (Broadfoot), who was seeking damages for mismanagement by Diaz, a former officer and director of the company. However, despite the best efforts of the trustee, Diaz could not be located to effectuate properly service of process. Service by email was upheld. | ||
| 2001 | ED VA | VA | Shri Ram Chandra Mission v. Sahajmarg.org | Email, mail, and publish | Must send a notice by postal mail and e-mail and must publish notice of the action as the court may direct promptly after filing the action. In this case, the court ordered plaintiff to publish notice of the lawsuit in “India Abroad, Indian Abroad Online, and the Washington Post—each at least once in the next two weeks. | Details |
| March 20, 2002 | United States Court of Appeals For the Ninth Circuit | CA | Rio Properties Inc. v. Rio International Interlink | Appeal to discredit previous e-service; court upheld eservice. The court reasoned that Rio's more traditional attempts at service (including registered international mail, return receipt requested) had failed and that Rio had established email as an effective means of communication with RII given that RII had communicated with Rio via email on two prior occasions. | Details | |
| May 31, 2002 | Western District of New York | NY | Ryan v. Brunswick Corp. | (finding service by regular mail, fax, and/or e-mail constitutionally permissible when defendant maintains website directing parties to communicate with it by regular mail, phone, fax, and e-mail). | Details | |
| 2002 | The New York Supreme Court of Oswego County | NY | Hollow v. Hollow | In this divorce proceeding, the defendant-husband relocated to Saudi Arabia and boasted via e-mail to his wife that “there’s nothing anyone can do to me here.” The wife petitioned the court to authorize service pursuant to section 308(5) of the New York Civil Practice Law and Rules.84 | ||
| Mar 28, 2003 | Northern District of California | CA | Viz Communications, Inc. v. Redsun | The plaintiff petitioned the court to serve the defendants—a Japanese entity and an individual residing in Japan—by e-mail after it unsuccessfully tried to serve them at several addresses listed on the defendants’ domain name registry | ||
| 2004 | Eastern District of Tennessee | TN | Popular Enters., LLC v. Webcom Media Group, Inc. | The Eastern District of Tennessee permitted the use of e-mail service in another trademark infringement case | ||
| June 3, 2004 | United States District Court Southern District New York | NY | D.R.I., Inc. v. Dennis | |||
| May 11, 2005 | United States District Court Southern District New York | NY | Export-Import Bank of U.S. v. Pulp & Paper Co. | |||
| October 11, 2005 | US District Court | WV | Williams v. Adver. Sex LLC | Past efforts to serve defendants were unsuccessful; plaintiff granted permission to serve via email | Details | |
| Jan. 6, 2006 | Eastern District of Wisconsin | WI | D’Acquisto v. Triffo | The Eastern District of Wisconsin authorized service of process via e-mail under Rule 4(f)(3).76 The court directed e-mail service mainly because it appeared the defendant was avoiding service, the plaintiff’s previous service attempts had failed, and the parties had previously communicated by e-mail. | ||
| June 13, 2006 | United States District Court Southern District New York | NY | Bank of Credit & Commerce Int'l (Overseas) Ltd. v. Tamraz, | |||
| 2007 | SD TX - Federal | TX | Nabulsi v. Al Nahyan | Referring case - Keller Williams V Lappeer | Details | |
| January 26, 2007 | D Guam | Nanya Tech. Corp. v. Fujitsu Ltd. | Nabulsi v. Al Nahyan | Defendant avoided service but had working email; service granted | Details | |
| April 17, 2007 | CA | Northern District of California | Williams-Sonoma Inc. v. Friendfinder Inc., | Sued to prevent namesake from being used in metatags on porn sites. Williams-Sonoma asked the court for an order authorizing it to serve process in the manner in which Williams-Sonoma had already been able to communicate with the defendants – by e-mail. The court granted the request. | Details | |
| March 12, 2007 | NY | United States District Court Southern District New York | Philip Morris USA Inc. v. Veles Ltd | Email and fax | Trademark infringement case; service by email granted | |
| Apr. 24, 2007 | NY | SD NY | Navalmar (U.K.) Ltd. v. Welspun Gujarat Stahl Rohren, Ltd., | Allows email service only after personal service was effectuated | Details | |
| Apr. 4, 2008 | NY | Civil Court of City of NY | Snyder v. Alternate Energy Inc | Required that plaintiff email 2 consecutive days with specific subject line AND call defendant to notify him of email | Details | |
| Jan. 30, 2008 | DC | US District Court | Juniper Networks, Inc. v. Bahattab | Email and fax | Attempted traditional service; couldn't locate defendant; service granted via email and fax | Details |
| Sep. 4, 2008 | CA | ND CA | LDK Solar Securities Litigation - Securities Class Action Clearinghouse | I hereby certify that on this date, I electronically filed the foregoing with the Clerk of the 4 Court using the CM/ECF system which will send notification of such filing to the e-mail addresses of the parties of record. I further certify that Service Pursuant to Civil Local Rule 23-2 will be made electronically to: Securities Class Action Clearinghouse Att. Juan-Carlos Sanchez/Cara Mia Perlas Stanford University School of Law Crown Quadrangle Stanford, CA 94305-8612 [email protected] | Details | |
| Feb. 13, 2008 | CA | ND CA | Bank Julius Baer & Co. v. Wikileaks | Defendant avoided service but had working email; service granted | Details | |
| July 31 2008 | TX | SD TX Houston | Keller Williams Realty, Inc. v. Lapeer | Email service granted | Details | |
| Dec. 1, 2008 | IL | ND ILL | MacLean-Fogg Co. v. Ningbo Fastlink Equipment Co., Lt | Email and fax | Plaintiff issued motion requesting service by email be allowed retroactively; court denied that but allowed plaintiff to reserve via email and fax per order | Details |
| Apr. 29, 2010 | FL | Southern District of Florida | 1 Cf. Chanel, Inc. v. Zhixian | Email-with restrictions | permitting e-mail service of process, but requiring service by publication as well given the limitations of e-mail) | |
| October 12, 2010 | CA | ND CA | Libyan Jamahiriya Broadcasting Corporation vs. Abdalla Saleh | Defendant avoided service but had working email; service granted | Details | |
| May 10, 2011 | MN | Fourth District Family Court of Minnesota | Mpafe v. Mpafe | Email, Facebook, Myspace, or any other social networking site | Divorce; SOP approved via various social media sites | |
| February 11, 2013 | FL | Southern District of Florida | U.S. Commodity Futures Trading Commission v. Alcocer et al | Delivery of package and email to several email addresses | Details | |
| March 7, 2013 | NY | United States District Court Southern District New York | FTC v. PCCare247 Inc. | Email and Facebook | After some difficulty in effecting service of the summons and complaint on the defendants in India, the FTC asked the court for leave to serve the remainder of the documents in the case (e.g., additional pleadings, motions, notices) via email and Facebook. The court granted the FTC’s motion. | Details |
| December 12, 2013 | OH | United States District Court Southern District of Ohio Western Division | Lexmark International, inc. v. Ink Technologies Printer Supplies, LLC, et al | Serve foreign defendants via email | Details | |
| February 4, 2014 | NY | United States District Court Southern District New York | Delama GEORGES et al., Plaintiffs, v. United Nations et al. | Specifically, by certified mail, return receipt requested; facsimile; and electronic mail— because service by traditional means has proved impracticable. | Details | |
| February 20, 2014 | VA | USDC for Eastern District of Virginia | WhosHere, Inc. v. Orun | Email, Facebook and LinkedIn | Motion granted | Details |
| September 12, 2014 | NY | Family Court of the State of New York County of Richmond | Noel Biscocho v. Anna Maria Antigua | Custody case; other methods proved unsuccessful; FB approved | Details | |
| March 27, 2015 | NY | Supreme Court, New York County | Ellanora Arthur Baidoo v. Victor Sena Blood-Dzraku, Defendant | divorce; service by facebook allowed | Details | |
| April 13, 2015 | NY | Dutchess County | Matter of Sucich 2015 NY Slip Op 50523(U) | Email and Mail | Probate court; nephew fled to Mexico | Details |
| May 29, 2015 | NY | S.D.N.Y | AMTO, LLC v. Bedford Asset Management, LLC | Motion granted to effectuate service of the Third-Party Summons and Complaint on Kuznetsov without the necessity of translation into the Russian language by email upon Kuznetsov at the Email Address, specifically [email protected] | Details | |
| May 29, 2015 | DC | Superior Court of the District of Columbia Civil Division | Text Message and Email | District of Columbia Superior Court Judge Laura Cordero ordered that an evasive defendant could be served through text message and email in a stalking and harassment case. | Details | |
| September 14, 2015 | FL | SD FLA | Stat Medical Devices, Inc. v. HTL-Strefa, Inc. | The plaintiff may serve by email the summons and complaint on the foreign defendant and its president at their respective email addresses and serve the summons and complaint on the domestic defendant's attorney. | Details | |
| November 27, 2015 | NY | SDNY | Sulzer Mixpac AG v. Medenstar Industries Co., Ltd. | The Court hereby grants plaintiff's motion to serve defendant by email at [email protected], but denies plaintiff's proposal to serve defendant by postal mail | Details | |
| December 7, 2015 | AZ | District Court AZ | Hydentra HLP Int. Ltd. vs. Porn69.org | Defendant avoided service but had working email; service granted | Details | |
| March 10, 2016 | NY | United States District Court, S.D. New York. | Fisher v. Petr Konchalovsky Foundation | Fisher requests that the Court permit him to serve the Foundation via email. He alleged that the foundation wrongfully declared the oil painting by Petr Konchalovsky he owned a fake | Details | |
| September 26, 2016 | NY | Family Court Onondaga County | Matter of J.T. 2016 NY Slip Op 26286 | Established history of use w/ email; defendant regularly moved | Details | |
| September 30, 2016 | CA | United States District Court Northern District of California | St. Francis Assisi v. Kuwait Finance House; Kuveytturk Participation Bank Inc., Hajjaj Al Ajmi; and Does 1 to 200 | In a September 30th ruling, U.S. Magistrate Judge Laurel Beeler of the Northern District of California invoked Rule 4(f)(3) to order that the plaintiff be allowed to use Twitter to serve process on the Kuwaiti national | Details | |
| 2016 | DC | DC Courts | Bazarian Int’t Fin. Assoc. v. Desarollos Aerohotelco, et. al., | Details |
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