WireSprout LLC v. Ming Cong Zhan, 2:24-cv-00925

Wiresprout LLC alleges copyright infringement by Ming Cong Zhan (d/b/a Zuomeng) concerning protected sprinkler wiring and repair devices.
Defendant is located in Xiamen, China, and conducts business online through platforms like Amazon.
After Wiresprout notified Amazon of alleged infringement, Zhan filed a counter-notice, agreed to federal jurisdiction, and provided an email contact.
Wiresprout filed a motion for alternative service under Rule 4(f)(3), seeking permission to serve Zhan via email.
The court considered whether email service was appropriate under U.S. and international law given the circumstances.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Can service of process be effected by email	Service by email is reasonably calculated to give Zhan notice	Defendant did not oppose (agreed to electronic service and provided email)	Service by email is valid under Rule 4(f)(3)
Whether other methods must be exhausted first	Rule 4(f) does not require plaintiff to try other service methods	Not contested	No requirement to exhaust other methods before 4(f)(3)
Compliance with due process	Email is reliable and likely to give notice given online business	Not contested	Email service comports with due process
Prohibition by international agreement	Hague Convention does not prohibit email service	Not contested	Email service is not prohibited by international agreement

Rio Properties, Inc. v. Rio Int'l Interlink, 284 F.3d 1007 (9th Cir. 2002) (Email service can satisfy due process and Rule 4(f)(3))
Mullane v. Central Hanover Bank & Trust Co., 339 U.S. 306 (1950) (Notice reasonably calculated to apprise parties required for due process)