Probably true in this case, but I am making a broader point about how to think about service by alternate means in such cases.

As for takedowns on search engines and social media, since all the big players like Google and Facebook are U.S.-based anyway, isn’t a U.S. judgment quite useful on that front? If he can’t do something against rando Lithuanian search engines or social media companies, who are bit players anyway, it doesn’t seem like that big a deal.

Since this is a TM or at least TM-adjacent claim, I also think you sort of have to be vigilant about pursuing infringers once they come to your attention. Otherwise you may risk vulnerability to some equitable defenses like estoppel, laches, waiver, etc. if you are lax with enforcement on repeated occasions.

Finally, although I’ll never be in that situation, I imagine that if I were a very rich celebrity and scammers were falsely using my identity to hock their products, I’d be quite furious. And, of course having the funds to do so, I would go after them just on principle, if nothing else.

PS: According to this article, Eastwood served the defendants by Skype too!

https://www.law360.com/articles/1382803/clint-eastwood-seeks-default-win-in-cbd-fraud-suit