Case of the day: Dinwang Jia v. Individuals on Schedule A


The case of the day is Dingwang Jia v. The Individuals, etc., Identified on Schedule A (S.D. Fla. 2026). This is yet another “Schedule A” case, raising what is now the classic issue about service of process by email on a Chinese defendant.

The case is interesting because of the treatment of the Chinese defendant’s address. The Hague Service Convention, remember, simply does not apply if the defendant’s address is unknown, and so the limitations the Convention imposes on service by email also do not apply if the defendant’s address is unknown. The defendant’s address was listed in its Amazon page, which you might think would be the end of the issue. But the plaintiff argued that he hadn’t been able to verify the address using the China Mainland Business Registry, apparently because the Amazon page didn’t give the defendant’s name in Chinese. Anyway, it doesn’t seem that the plaintiff tried to serve process via the Chinese central authority once it decided that the address could not verified.

It seems to me that the plaintiff outsmarted himself here. If the website gives an address, rather than undertaking investigations and making motions for leave to serve by alternate means and then fighting motions challenging the validity of the service, why not just ask the central authority to serve process at the address given? The judge didn’t take this approach though. Instead, she concluded that the plaintiff had not used reasonable diligence to discovery the defendant’s address, and therefore, that the address was not “unknown” for purposes of the Convention. The right result, but a questionable path to it.

Fediverse reactions

2 responses to “Case of the day: Dinwang Jia v. Individuals on Schedule A”

  1. Michael La Porte

    Without any analysis, Judge Bloom also assumed that the Hague Service Convention applied – departing from her numerous earlier decisions holding that China’s failure to object to e-mail allowed such service. Without much fanfare, this is quite the reversal in the SDFLA – a venue that Sched. A. plaintiffs may try to retreat to now that 2nd Cir and 7th Cir have become inhospitable on the service front.

    DISLOSURE: I was the defense attorney for HYHA in this case.

    1. Thanks for commenting! You are right that the opinion lacks any real explanation of why the Convention bar service of process by email in China when the defendant’s address is known. At some point I hope we will have an Eleventh Circuit opinion, but it may not be anytime soon!

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