In December I wrote about the First District's decision in Richardson v. Clinical Computing PLC, in which the court held that a treaty (the "Hague Convention on Service Abroad of Judicial and Extrajudicial Documents in Civil or Commercial Matters") permitted service of a complaint and summons by regular mail in the United Kingdom. I also noted that there was a split of authority on the question.
Today the US Supreme Court resolved that split, holding in Water Splash v. Menon that the treaty does indeed permit service of process through regular mail.
A tip of the cap is due to former First District Judge Peter Stautberg, who nailed the analysis in his decision.
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