The case of the day is Patrick’s Restaurant LLC v. Singh (D. Minn. 2018). Patrick’s sued Sujit Kumar Singh for breach of contract, on account of an alleged failure to make a promised capital contribution to the business in return for a membership interest. Singh resided in Mumbai. Singh was represented by US counsel and was on notice of the lawsuit, but he refused to waive service. Patrick’s sent a request for service to the Indian central authority, but seven months later, service had not been effected. Patrick’s moved for leave to serve by alternate means under FRCP 4(f)(3), namely, by email.