that 120 days is a reasonable limit “since the method of service did not present any unusual difficulties.” Id. Plaintiff responds that it served the Amended Complaint within the 120-day deadline and that even if the Court were to determine that service of the original Complaint was outside of the 120-day window, that service was reasonable as Defendant was not harmed in any way by the delay. See Opp. at 7-11. The Court agrees with Plaintiff. As both parties recognize, the 120-day window for service does not apply to Defendant given its status as a foreign entity. Mot. at 10; Opp. at 7. Instead, the Court should apply a standard of “flexible due diligence.” See Overseas Partners, Inc. v. PROGEN Musavirlik ve Yonetim Hizmetleri, Ltd. Sikerti, et al., 15 F.Supp.2d 47, 49-50 (D.D.C.1998) (<HOLDING>); James v. Rutil, No. 95-530, 1997 WL 151174,
holding that in a proceeding to terminate parental rights the preponderance of the evidence standard of proof violates the due process clause and that due process requires at least a clear and convincing evidence standard holding that foreign states are not persons entitled to rights under the due process clause recognizing implied obligation to use reasonable diligence recognizing flexible due diligence standard for determining whether service of process on foreign national was timely holding that the facts did not measure up to the standard expressed for determining procedural due process