On November 11, 2015, the Court of Justice of the European Union (Court) issued a judgment [3] deciding the interpretation of what constitutes an “extrajudicial document.” According to the press release [4], the case concerned an EU Regulation [5] which states that “[t]he proper functioning of the internal market entails the need to improve and expedite the transmission of judicial and extrajudicial documents in civil or commercial matters for service between the Member States” and requires member states to transmit those documents “directly and by rapid means.” The Court found that “the concept of an ‘extrajudicial document’ referred to in that article encompasses not only documents drawn up or certified by a public authority or official but also private documents of which the formal transmission to an addressee residing abroad is necessary for the purposes of exercising, proving or safeguarding a right or a claim in civil or commercial law.” The Court further decided that a party was “perfectly entitled not only to choose any of the means of transmission laid down by Regulation . . ., but also to resort, simultaneously or successively, to two or more of the methods of service which he deems the most suitable or appropriate in the light of the circumstances of the case.” Finally, the Court stressed that if the conditions for the application of the regulation are triggered, the national authorities must transmit that document automatically, without having to “ascertain, on a case-by-case basis, whether the service of an extrajudicial document has cross-border implications and is necessary for the proper functioning of the internal market.”