3. Rule 4(f)(3) authorizes forms of service “by other means not prohibited by international agreement, as the court orders.” Service of process under Rule 4(f)(3) is neither a “last resort”

nor considered to be “extraordinary relief”; this form of service is not to be “disfavored.” 4B Wright & Miller, Federal Practice and Procedure: Civil 3d § 1134. Courts have ordered a variety of means for service, including ordinary mail, publication, and delivery of process to defendant’s attorney. Electronic means of service of process also may be permitted.

Even before the 1993 amendment to the Federal Rules, the trial court in New England Merchants National Bank v. Iran Power Generation andTransmission Co., 495 F.Supp. 73

(S.D.N.Y. 1980), ordered service of process on Iranian defendants by telex. Since then, trial courts have authorized service by email. In RIO PROPERTIES, INC. v. RIO INTERNATIONAL INTERLINK, 284 F.3d 1007 (9th Cir. 2002), defendant operated an Internet gaming business, and posted an email address on its website. The court permitted email service after plaintiff had unsuccessfully attempted service in the United States, in Costa Rica, and on the international courier designated as an address when defendant registered its website.