What constitutes proper service?

In

Australia, a court granted a process server to serve documents on a case via facebook.  In the

US
, a woman was being served by a process server, but she would not open her door. The process server saw the subject sitting in her kitchen shredding lettuce and washing it in a colander.  The process server tossed the summons through an open window and the summons landed in the colander.  When the case went to court the judge stated that was the most creative way to get a summons in front of someone and that it was proper service.  What would you say is proper service? 

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