Rio Properties, Inc. v. Rio International Interlink (284 F.3d 1007 [9th Cir 2002]) upheld the service of process upon an international defendant accomplished by e-mail. The plaintiff had attempted to serve defendant by conventional means, but the defendant preferred communication only by e-mail. The federal appellate court held that such service did not even have to be reserved as a last resort; it simply permitted trial courts to consider all factors and circumstances in ruling on the propriety of any particular service.