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Published online by Cambridge University Press: 27 February 2017
1 Julen v. Larson, 25 Cal. App. 3d 325, 101 Cal. Rptr. 796 (2d Dist. 1972) (service from Switzerland made in German language).
2 Shoei Kako Co., Ltd. v. Superior Court, San Francisco 33 Cal. App. 3d 808, 109 Cal. Rptr. 402 (1st Dist. 1973) (service made in Japan by registered mail with return receipt).