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N.D. Cal.Procedural orderFiled Dec. 5, 2022

Zapier, Inc. v. Clickdesk, Inc.

Judge
Jeffrey White
Docket
4:22-cv-04811
Court
U.S. District Court · Northern District of California
Pages
3
Civil Procedure
In one sentence

In Zapier v. Clickdesk, Judge White allowed alternative service by email and social media and extended Zapier’s deadline to serve the defendants.

Who this affects

Zapier, Inc., Clickdesk, Inc., Agile CRM, and Manohar Chapalamadugu.

What happened

In Zapier, Inc. v. Clickdesk, Inc., the court considered Zapier’s request to serve Clickdesk, Agile CRM, and Manohar Chapalamadugu through email and social media instead of only traditional methods.

The court found that these methods were reasonably likely to notify the defendants about the lawsuit and give them an opportunity to respond. It allowed Zapier to email the case documents to Clickdesk and Agile CRM and send Chapalamadugu a message with a link to the documents through LinkedIn, Twitter, and Facebook.

The court also extended Zapier’s service deadline to six months from the order’s date and required Zapier to file a notice and declaration describing the electronic service within 14 days. Judge Jeffrey S. White granted the motion.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Zapier, Inc. v. Clickdesk, Inc. · No. 4:22-cv-04811
Judge
Jeffrey White
Date
Dec. 5, 2022

Background

Zapier asked for permission to use alternative service under Rules 4(f)(3), 4(h)(2), and 4(e)(1) of the Federal Rules of Civil Procedure. The request covered service on Clickdesk, Inc.; Agile CRM; and Manohar Chapalamadugu. Zapier also requested more time to serve the defendants.

Ruling

The court granted the motion. It held that the proposed methods were “reasonably calculated to notify” the defendants about the lawsuit and give them an opportunity to present their answers and defenses. The court also stated that the methods were not prohibited by an international agreement.

The order authorized Zapier to send the service documents by email to Clickdesk at info@clickdesk.com and support@clickdesk.com, and to Agile CRM at care@agilecrm.com and sales@agilecrm.com. It authorized Zapier to send Chapalamadugu a message containing a hyperlink to an online repository with the service documents through his LinkedIn, Twitter, and Facebook accounts.

The court required Zapier’s counsel to file a notice of electronic service supported by a signed declaration stating when, how, and at what time service was completed. That filing was due within 14 days of the order. The court also gave Zapier six months from the order’s date to complete service and instructed Zapier to continue pursuing service under the Hague Convention. Judge Jeffrey S. White granted the motion.

The authoritative version

Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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