4. New forms of technology continue to affect the forms of process that are considered permissible. In FEDERAL TRADE COMMISSION v. PCCARE247 INC., 2013 WL 841037

(S.D.N.Y. 2013), service of process upon defendants located in India was permitted through email and Facebook. Defendants were alleged to have operated a scheme out of call centers in India designed to trick consumers in the United States to fix non-existent computer problems. The court found that service by email would comport with due process, but raised questions whether service by Facebook alone would be constitutionally sufficient, underscoring the difficulty of confirming that a Facebook page actually belongs to the defendant to be served. Service by Facebook was permitted by an Australian court in a breach of contract suit against Flo Rida, a United States rap star, who was alleged to have made a

“nonappearance” at the “Fat as Butter” Concert at Camp Shortland, Australia. Facebook service was permitted because defendant had left the jurisdiction after the suit commenced, and multiple attempts at personal service had failed. See Mothership Music Pty Ltd. v. Ayre,

[2012] NSW DC 42 (Austl.).