The case of the day is Reflex Media, Inc. v. Apiriliaco, Ltd. (9th Cir. 2018). The case illustrates nicely the distinction drawn in Water Splash v. Menon between methods of service that the Hague Service Convention authorizes, and methods of service that the Convention merely permits. Reflex served process on Apiriliaco in Cyprus via mail—sent by the plaintiff or its lawyer, not the clerk. Cyprus is a party to the Convention and has not objected to service by postal channels. Reflex then obtained a default judgment, and Apiriliaco appealed.