Race Tires America v. Hoosier Racing Tire Corp.
United States District Court for the Western District of Pennsylvania
2011 WL 1748620 (2011)
- Written by Rich Walter, JD
Facts
Specialty Tires of America, Inc. (Specialty Tires) (plaintiff), the corporate parent of the named plaintiff, Race Tires America, Inc., sued Hoosier Racing Tire Corporation (Hoosier) (defendant) in federal court. In electronic discovery (e-discovery), Specialty Tires pushed for the production of massive amounts of electronically stored information (ESI) in Hoosier’s possession. Specialty Tires lost its case and, under Federal Rule of Civil Procedure 54, had to reimburse Hoosier for litigation costs enumerated in the general taxation-of-costs statute codified at 28 U.S.C. § 1920. The court clerk, citing § 1920(4), included Hoosier’s e-discovery expenses in Specialty Tires’ bill of costs. Section 1920(4) provided that a prevailing party could recover “[f]ees for exemplification and the costs of making copies of any materials where the copies are necessarily obtained for use in the case.” Specialty Tires moved for a review of the clerk’s assessment. The court granted the motion to the extent that it reviewed the assessment de novo and, with minor adjustments, accepted the assessment as reasonable. The court then turned its attention to Specialty Tires’ argument that § 1920(4) did not encompass e-discovery expenses.
Rule of Law
Issue
Holding and Reasoning (Scheindlin, J.)
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