P Smith, I think this is a little more complicated. There is no question that the notice is a “judicial document,” but what does the Convention mean when it says “for service abroad?” As I stated, my view generally has been the same as yours, namely, that service abroad means delivery abroad, and in general, I agree that this poses no problems, since usually documents after the initial process are not required to be served abroad. But it is not easy to find good authority on this point, and in practice courts sometimes do not apply the Convention as you suggest they should. This is the motivation for wondering whether “for service abroad” should be read to mean “for formal service abroad,” or “for service of process abroad.”

This covers any document required to be served in civil proceedings, although normally at stages subsequent to the initial summons a defendant making an appearance will have supplied an address for service within the court’s jurisdiction or agreed to methods of service which don’t require transmission of documents abroad.

Thus the Convention does apply to the notice of judgment lien required to be served here, and direct mail is sadly not an option in view of Switzerland’s objection to use of the methods listed in Article 10.

I would question whether FRCP 4 is relevant here, since either the “state practice or procedure” which requires service of a document in the course of enforcing a judgment permits a method of service, either as of right or with the court’s permission which the federal court can give by virtue of FRCP 69 itself; or it does not permit a method of service, in which case FRCP 69 prevents the federal court from authorising it under FRCP 4.