In Water Splash, Inc. v. Menon, 137 S. Ct. 1504 (U.S. 2017) (No. 16-254), plaintiff sued one of its former employees in Texas state court, alleging that she had begun working for a competitor while still employed by plaintiff.  The defendant resided in Canada, and plaintiff served her by mail.  Defendant declined to answer or otherwise appear, and the trial court issued a default judgment.  On appeal, defendant argued that service by mail does not comport with the requirements of the Hague Service Convention, and the Texas Court of Appeals agreed, holding that service by mail was improper.  The US Supreme Court reversed, holding that the Convention does not prohibit service by mail.  Articles 10(b) and (c) of the Convention authorize service by certain methods, but do not mention mail; and Article 10(a) provides that the Convention shall not interfere with “the freedom to send judicial documents, by postal channels,” but does not expressly refer to “service.”  Despite this textual difference, the Court determined that Article 10(a) should be interpreted broadly, finding that there was no apparent reason why it would exclude the sending of documents for any particular purpose, namely service.  The Court further reasoned that the scope of the entire Convention is limited to service of documents, and that it would be “quite strange” if Article 10(a) – apparently alone among the Convention’s other provisions – concerned something other than service of documents.  The Court rejected the argument that Article 10(a) does not apply to service of process but instead applies only to the sending of post-answer judicial documents that have to be served later in the litigation, concluding that there was no textual footing for making that distinction.