... [was] primarily guided by [its] recognition of established and fundamental principals of international law.” Id. Unlike Compagnie, the facts of the discovery dispute here do not implicate established and fundamental principles of international law. Accordingly, Compagnie is of little assistance in resolving the question presented in the instant ease. Id. Thus, candor requires an acknowledgment that the conelusory holding of a majority of courts appears to be that Rule 45 requires personal service of subpoenas. Nevertheless, a minority of better reasoned eases recently have challenged the wisdom of the majority view and have instead held that personal service is not required — a position Plaintiff urges this Court to adopt. See e.g., Doe v. Hersemann, 155 F.R.D. 630 (N.D.Ind. 1994) (<HOLDING>); Ultradent Products, Inc. v. Hayman, 2002 WL
holding that if service done by certified mail action commenced upon receipt of summons and complaint holding that because alternative service by means of certified mail reasonably insures actual receipt of the subpoena by the witness the delivery requirement of rule 45 will be met holding that inhand delivery is not required under rule 45 so long as service is made in a manner that reasonably insures actual receipt of the subpoena holding that service of a subpoena via certified mail is sufficient under rule 45 particularly when defendant does not deny actual receipt holding that delivery of subpoena via federal express was sufficient because effective service under rule 45 is not limited to personal service