By Daniel Prince, Serli Polatoglu and Nate Brown (August 31, 2018, 12:56 PM EDT) -- On Aug. 23, 2018, the Ninth Circuit Court of Appeals upheld the U.S. government's attempt to serve a criminal summons on Pangang Group Company Ltd. and its subsidiaries, which are owned and operated by the Chinese government. In doing so, the Ninth Circuit held that service was proper under the amended Federal Rules of Criminal Procedure because the Pangang companies had sufficient notice of the summons through their attorneys — a means of service courts previously held did not comport with Federal Rule of Criminal Procedure 4. By holding that service of the summons upon the Pangang companies' attorneys was sufficient, the Ninth Circuit has broadly interpreted the service requirements for foreign organizations, meaning that such organizations may have more limited options in contesting service of a criminal summons in the future....