In these federal cases Plaintiffs could not locate
Defendant in California for personal service of process,
because at all times Defendant was a resident and citizen
of China. Plaintiffs had reasons to know or suspect
that Defendant was in China, but made no effort to
locate her there. The District Court permitted either
substituted service in California, or service by publication
in California, pursuant to California law under Federal
Rule of Civil Procedure 4(e)(1). This resulted in default
judgments against Defendant.

When Plaintiffs have reason to believe that Defendant
may be located and served in a foreign country, do the Due
Process Clauses of the Fifth and Fourteenth Amendments
require Plaintiffs to conduct a reasonably diligent search
for Defendant in that foreign country before substitute
service or service by publication are permissible?

Due process-requirements-for-service-of-process-on-foreign-defendants