Kotodama, thanks for this. I think that the law really does focus on where the service takes place, mainly because one of the key issues here is that deciding whether the service takes place in the United States or abroad is key to deciding whether The Hague Service Convention applies (see Article 1 of the Convention, which is keyed to transmission of documents abroad for service), and because it is against the law in many countries to serve process in their territory except through their judicial officers. But you are right to point to the troublesome issue of trying to locate a corporation in physical space, which is a problem not just in the service context but also in the context of personal jurisdiction and the context of diversity of citizenship.

I guess what I’m trying to say is, maybe the rule focuses more on the location of the party itself and not the quasi-metaphysical “location” where service took place? Of course, as always this isn’t my area of expertise at all, and if the latter is correct, then I agree “fancy footwork” is required for it to make sense.

I will just note in closing this is an Albright case, so it’s definitely no surprise he found a way to rule in favor of the patentee plaintiff.