What is the test for a defendant's claim that a default judgment is void because it awards damages in breach of due process?

due process requires formal notice of potential liability. (Ibid.) "[A]ctual notice does not substitute for service of an amended complaint specifying the amount of damages sought." (Ibid.; see also Matera v. McLeod(2006) 145 Cal.App.4th 44, 59-60 & Electronic Funds Solutions, LLC v. Murphy (2005) 134 Cal.App.4th 1161, 1173.) Finally, a defendant's claim that a default judgment is void because it awards damages in violation of the due process principles embodied in section 580 may be raised for the first time on appeal. (Matera, supra, at p. 59.)