Not a fan of this:
Rule 60(c)(1) accommodates such a scenario by imposing a reasonable-time requirement, rather than a fixed time limit. And in the context of a default judgment, it might be reasonable for a defendant not to seek relief before learning about a plaintiff ’s attempted enforcement.
That's basically letting the courts decide when it's reasonable to start the clock, like they did in this case.
As part of these efforts, the trustee sent a demand letter to the company’s CEO in April 2016. Lower courts concluded that this letter gave Coney Island notice of the judgment and the trustee’s enforcement efforts.
OK, but they still haven't been
served. The opinion doesn't cover the specifics, or include something like "Coney Island agreed that this is when they became aware". The rest of it makes it sound like Coney Island might have succeeded in challenging the judgement but they wound up arguing the wrong technical objections.
I'm autistically focusing this because Null has had similar garbage happen to him. A default judgement when he wasn't aware he was being sued, or
pro se idiots trying to service by email to the wrong address. He's been a bit lucky with how most judges deal with those cases, but you don't want to depend on luck for these things.