facts to dispute the existence of an agreement, and “general objections to the

existence of a contract” are “insufficient to satisfy the meritorious defense

requirement.” NewGen, LLC v. Safe Cig, LLC, 840 F.3d 606, 616 (9th Cir. 2016)

(internal quotation marks omitted).

Defendants also lack a meritorious defense to Zurich’s breach of fiduciary

duty claim. Defendants do not dispute that Sealink failed to maintain the

premiums it owed Zurich in a segregated trust account as required by California

Insurance Code sections 1733 and 1734. Defendants’ argument that those

provisions do not provide Zurich with a cause of action is mistaken. See Middlesex

Insurance Co. v. Mann, 177 Cal. Rptr. 495, 503 (Ct. App. 1981) (“We conclude

that a civil action will lie for damages proximately resulting from a licensee’s

breach of the fiduciary obligations imposed by [sections 1733 and 1734].”).

Finally, defendants fail to assert a meritorious defense to the size of the

default judgment award. The district court determined that the declaration of

Zurich’s legal collection specialist and the billing statement generated by Zurich Page 4 of 5

constituted “proof sufficient to support [Zurich’s] requested damages.”

Defendants’ challenge to the sufficiency and reliability of that evidence does not

amount to a meritorious defense. See Franchise Holding II, LLC v. Huntington

Restaurants Group, Inc., 375 F.3d 922, 926 (9th Cir. 2004) (a “mere general

denial” regarding the extent of the deficiency owed “is not enough to justify

vacating a default or default judgment” (internal quotation marks omitted)).

Defendants fail to offer specific facts disputing the damages amount despite being

“in the best position to have the accurate records required to refute” Zurich’s

evidence. NewGen, 840 F.3d at 617. Defendants’ assertion that they lack records

substantiating the claimed amount does not amount to an allegation of “sufficient

facts that, if true, would constitute a defense.” Mesle, 615 F.3d at 1094.

2. The district court did not err in failing to set aside the default judgment

pursuant to Federal Rule of Civil Procedure 60(b)(4). Rule 60(b)(4) provides for

relief when a judgment is void. In contrast to the other grounds for relief under

Rule 60(b), a default judgment may be vacated on this ground even if the

defendant lacks a meritorious defense. See Thos. P. Gonzalez Corp. v. Consejo

Nacional de Produccion de Costa Rica, 614 F.2d 1247, 1256 (9th Cir. 1980).

Defendants argue that the judgment is void due to inadequate service of process.

But Zurich’s service of process satisfied the statutory requirements. Zurich’s

substituted service of the summons and complaint on Zhang was proper under Page 5 of 5

Federal Rule of Civil Procedure 4(e)(1) and California Code of Civil Procedure

section 415.20(b). Zurich’s service of the summons and complaint on Sealink

complied with Federal Rule of Civil Procedure 4(h)(1)(B). Finally, Zurich served

both Zhang and Sealink with its motion to enter default judgment in accordance

with the Central District of California’s Local Rule 55-2 and Federal Rule of Civil

Procedure 5(b)(2)(C).

AFFIRMED.