Panamerica Trade, Inc. v. Boys, 3:25-cv-00473

Panamerica Trade, Inc. ("Plaintiff") sued Christopher Boys, Food Service Gaskets, LLC, and RAC Industries, LLC in federal court in Florida.
Plaintiff sought to serve Boys, believed to be in the Philippines, with the Complaint and Motion for Preliminary Injunction via email after unsuccessful service attempts at his last-known address in Florida.
The process server was informed Boys no longer lived at the Florida address; Plaintiff's president had previously communicated with Boys through the email address in question.
Plaintiff moved for alternative service under Federal Rule of Civil Procedure 4(f)(3), requesting permission to use email since Boys was believed to reside abroad.
The central question was whether email service on a defendant in the Philippines is allowed under international law, given that the Philippines is a party to the Hague Convention and has objected to certain service methods.
The court noted a lack of Eleventh Circuit authority on whether email service is allowed under these circumstances, and found federal courts are split on the issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
May the Court permit service via email on Boys in the Philippines under Rule 4(f)(3)?	Email is not prohibited by international agreement; discretion allows for email service.	Not present / No response recorded.	Motion for alternative service via email denied without prejudice; more attempts at Hague Convention service were needed.

Prewitt Enters., Inc. v. Org. of Petroleum Exporting Countries, 353 F.3d 916 (11th Cir. 2003) (district court has discretionary authority to order alternative service under Rule 4(f)(3))