text4946_01 text4946_02 text4946_03


After summary judgment, prevailing party E. & J. Gallo submits bill of costs for ediscovery processing.  Circuits are split as to eligibility of ESI costs unter 1920(d).  In this case the fourth circuit found Race Tires America (Third Circuit) persuasive and held that ESI processing is not “making copies” – only making copies can be reimbursed.