Plaintiff sued a Japanese medical equipment manufacturer for a malfunction that allegedly damaged her kidneys. Plaintiff attempted to serve the defendant by serving the defendant's subsidiary in Illinois, and also by sending the summons and complaint via FedEx to Japan.
The court found that the service of process was insufficient under California law. California Code of Civil Procedure does allow service of process on a parent corporation by serving the subsidiary if the subsidiary is the "general manager" of the parent. But the court found that the plaintiff did not sufficiently describe the corporate relationship between the Japanese parent and the Illinois subsidiary.
California's "general manager" rule is rather adventurous--a potential counter-point to Litigation Isolationism. But it is interesting that the court is requiring a more rigorous set of facts. In such a case, would a court a pre-merits discovery (like jurisdictional discovery) to see if a service on subsidiary is valid?