J&H Web Technologies, LLC v. Square Cat Software Limited

CourtDistrict Court, E.D. Texas
DecidedJanuary 31, 2025
Docket2:23-cv-00279
StatusUnknown

This text of J&H Web Technologies, LLC v. Square Cat Software Limited (J&H Web Technologies, LLC v. Square Cat Software Limited) is published on Counsel Stack Legal Research, covering District Court, E.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
J&H Web Technologies, LLC v. Square Cat Software Limited, (E.D. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION

J&H WEB TECHNOLOGIES, LLC, § § Plaintiff, § § v. § CIVIL ACTION NO. 2:23-CV-00279-JRG § SQUARE CAT SOFTWARE LIMITED § AND SQUARE CAT LIMITED, § § Defendants. § §

MEMORANDUM OPINION AND ORDER Before the Court is the Motion for Entry of Default Judgment and Permanent Injunction (“Motion for Default”) (Dkt. No. 11) and Motion for Leave to Effect Service by Mail Through the Texas Secretary of State (the “Motion for Leave”) (Dkt. No. 12) filed by Plaintiff J&H Web Technologies, LLC (“Plaintiff”). Having considered the Motion for Default, the Court finds that it should be and here is DENIED. Having considered the Motion for Leave, the Court finds that it should be and hereby is DENIED. I. BACKGROUND A. Procedural Background Plaintiff filed suit against Defendant Square Cat Software Limited (“S.C. Software”) on June 16, 2023. (Dkt. No. 1.) Plaintiff filed an Amended Complaint against Defendant S.C. Software on June 21, 2023. (Dkt. No. 3.) On July 6, 2023, the Clerk issued a summons as to Defendant S.C. Software. (Dkt. No. 4.) On July 7, 2023, Plaintiff served the summons and a copy of the original complaint on the Texas Secretary of State as the registered agent of Defendant S.C. Software. (Dkt. No. 5.) Plaintiff filed an affidavit of service with the Court on July 7, 2023. (Id.) The affidavit stated that the process server delivered the summons and original complaint “to: Michelle Robinson at 1019 Brazos Street, Austin, Travis County, TX 78701, as the designated agent for the Texas Secretary of State to accept delivery of process on behalf of Square Cat Software Limited.” (Id.) Plaintiff did not file an affidavit of service that it served the Amended

Complaint on the Texas Secretary of State. On November 8, 2023, Plaintiff filed a Second Amended Complaint against Defendants S.C. Software and Square Cat Limited (“S.C. Ltd.”) (collectively with S.C. Software, “Defendants”). (Dkt. No. 6.) On November 9, 2023, the Clerk issued a summons as to Defendant S.C. Ltd. (Dkt. No. 7.) On November 12, 2023, Plaintiff served the summons as to Defendant S.C. Ltd. and a copy of the Second Amended Complaint on the Texas Secretary of State as the registered agent of Defendant S.C. Ltd. (Dkt. No. 8.) Plaintiff filed an affidavit of service with the Court on February 23, 2024. (Id.) The affidavit stated that the process server delivered the summons and Second Amended Complaint “to: Minnie Barnhart, The Texas Secretary of State as Authorized Agent at the address of: 1019 Brazos Street, Austin, Travis County, TX 78701 on behalf of Square

Cat Limited.” (Id.) The affidavit of service is limited to Defendant S.C. Ltd. (Id.) On February 23, 2024, Plaintiff requested the Clerk of Court to enter default as to Defendants. (Dkt. No. 9.) The Clerk of Court entered an administrative finding of default as to Defendants the same day. (Dkt. No. 10.) On June 19, 2024, Plaintiff filed the Motion for Default, moving for entry of default judgment and permanent injunction against Defendants. (Dkt. No. 11.) On September 16, 2024, the Court held a telephonic status conference with counsel for Plaintiff. During that status conference, the Court informed Plaintiff that its service on Defendants via the Texas Secretary of State was improper. On December 12, 2024, Plaintiff filed the Motion for Leave, seeking leave to effect service on Defendant S.C. Ltd. by mail through the Texas Secretary of State. (Dkt. No. 12.) II. LEGAL STANDARD A. Service of Process on Foreign Entities The Federal Rules of Civil Procedure state that a foreign corporation served outside the United States must be served “in any manner prescribed by Rule 4(f) for serving an individual, except personal delivery under (f)(2)(C)(i).” Fed. R. Civ. P. 4(h)(2). Federal Rule of Civil

Procedure 4(f) provides that an individual in a foreign country may be served as follows: (1) by any internationally agreed means of service that is reasonably calculated to give notice, such as those authorized by the Hague Convention on the Service Abroad of Judicial and Extrajudicial Documents; (2) if there is no internationally agreed means, or if an international agreement allows but does not specify other means, by a method that is reasonably calculated to give notice: (A) as prescribed by the foreign country’s law for service in that country in an action in its courts of general jurisdiction; (B) as the foreign authority directs in response to a letter rogatory or letter of request; or (C) unless prohibited by the foreign country’s law, by: (i) delivering a copy of the summons and of the complaint to the individual personally; or (ii) using any form of mail that the clerk addresses and sends to the individual and that requires a signed receipt; or (3) by other means not prohibited by international agreement, as the court orders. Fed. R. Civ. P. 4(f). “Thus, so long as the method of service is not prohibited by international agreement, the Court has considerable discretion to authorize an alternative means of service.” Terrestrial Comms LLC v. NEC Corp., No. 6-20-CV-00096-ADA, 2020 WL 3452989, at *1 (W.D. Tex. June 24, 2020). However, even when “other methods of obtaining service of process are technically allowed, principles of comity encourage the court to insist, as a matter of discretion, that a plaintiff attempt to follow foreign law in its efforts to secure service of process upon defendant.” Id. (cleaned up). Further, to satisfy the constitutional requirement of due process, the method of service must be “reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action and afford an opportunity to present their

objections.” Id. (quoting Mullane v. Cent. Hanover Bank & Tr. Co., 339 U.S. 306, 314 (1950)). B. Default Judgment Federal Rule of Civil Procedure 55 governs the entry of default and default judgment. Default under Rule 55 is a two-step process: (1) the entry of default, and (2) the subsequent entry of a default judgment. See Fed. R. Civ. P. 55(b). Under Federal Rule of Civil Procedure 55(c), a court has discretion to set aside an entry of default where there is “good cause.” Fed. R. Civ. P. 55(c). However, even in the absence of “good cause,” the district court “must set aside the clerk of court’s entry of default as a matter of law” if the court lacks jurisdiction over the defendant due to improper service of process. Titan Glob. Holdings, Inc. v. Evan, 2008 WL 11435706, at *4 (N.D. Tex. Oct. 30, 2008); see also Rogers v. Hartford Life & Accident Ins. Co., 167 F.3d 933, 940 (5th Cir. 1999) (“When a district court lacks jurisdiction over a defendant because of improper service

of process, the default judgment is void and must be set aside.”). III. DISCUSSION A. Motion for Leave to Effect Alternative Service Plaintiff argues that the Court should grant it leave to serve Defendant S.C. Ltd. through the Texas Secretary of State. (Dkt. No.

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Related

Rogers v. Hartford Life & Accident Insurance
167 F.3d 933 (Fifth Circuit, 1999)
Mullane v. Central Hanover Bank & Trust Co.
339 U.S. 306 (Supreme Court, 1950)

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J&H Web Technologies, LLC v. Square Cat Software Limited, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jh-web-technologies-llc-v-square-cat-software-limited-txed-2025.