Recently, a story out of New York has been circulating across the internet involving a Manhattan Supreme Court Judge that permitted a woman to serve her husband with divorce papers through a private Facebook message. According to the story, the husband was a somewhat transient individual who lacked a fixed place of residence and was not employed. The woman and her attorney tried everything they could to get her husband served, but even a private detective was not able to locate the whereabouts of the husband. When the woman told the Judge that her communication with her husband was mostly through Facebook, the Judge decided that service through Facebook message was the new frontier of ensuring due process in the twenty-first century.