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Voice Tele Services Inc. v. Zee Telecoms Ltd.

Service on Defendant in London Was Proper Under Hague Convention, FRCP 4(h)(2)

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MEMORANDUM ORDER On July 12, 2019, the Court entered default judgment in favor of plaintiff Voice Tele Services Inc. (“VTS”) against defendant Zee Telecoms Ltd. (“Zee”). Dkt. No. 16. Now before the Court is Zee’s motion to vacate the default judgment order under Federal Rule of Civil Procedure 60(b)(4) on the basis that the default judgment is void for lack of personal jurisdiction, specifically improper service of process. For the reasons set forth below, the motion is denied. Background On June 4, 2019, VTS filed a two-count complaint against Zee, a United Kingdom company, for breach of contract and account stated. See Dkt. No. 1. The complaint alleged that Zee failed to pay for $350,378.93 in telecommunication services rendered by VTS to Zee under the terms of the parties’ agreement. Id. 1. On June 17, 2019, VTS filed a declaration of service in which a process server affirmed that he served Zee by leaving a copy of the summons, complaint, and the attached exhibit, with “Mr. Cooper, Director of Hold Everything at Zee’s registered office, located at 207 Regent Street, London, England, W1B 3HH, which is designated by law to accept service of process on behalf of Zee.” Dkt. No. 8, 2. Later that month, counsel for VTS emailed Zee’s founder, Rahim Mayet, copies of the summons and complaint. See Declaration of Shira Rosenfeld Grossman (“Grossman Decl.”), Dkt. No. 23,

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