Interesting observations, which could be right, though as you say the decision is quite unclear.

The only point I’ll raise about your comment is that service under article 10(b) or (c) is not solely a matter of the law of the forum–the question of who is competent to make the service under those articles is a question for the law of the state where the service is made, and the method of service at least must not be one forbidden by that law (since it is the officer of the foreign state who effects the service).

It seems to me that the plaintiffs intended to personally serve the defendant directly through a process server. This would have been in accordance with Article 10(b) or (c) of the Convention, as Venezuela’s objection is only to postal service under Article 10(a) (which, I note, is the only aspect of Article 10 that the court mentions in its discussion at 7-8).

Further, it seems to me that that is exactly what the plaintiffs actually did. As the Convention is silent on how the fact of service under any of the limbs of Article 10 is to be established, this must be a question solely for the court whose process is being served. Would not the process server’s affidavit have been sufficient for a US district court considering whether a defendant has been served in accordance with FRCP 4(f)(1)?

Thereafter the confusion begins, and I think they tried to turn their (successful) attempt at direct service into service by the central authority in accordance with Venezuelan law, which of course it was not. Hence the failure of the central authority to issue an Article 6 certificate: no actual request had been made.