Key Insight: Court denied Defendant?s request for e-discovery costs. Defendant?s vendor provided services to create optical character recognition (?OCR?) image and text files for Defendant?s productions. The Court concluded that the costs of creating electronic copies of documents are recoverable but the costs of creating a dynamic, indexed and searchable database that allows counsel to search for and within the documents are not recoverable. The Court denied Defendant?s recovery of costs for the technical services provided by their e-discovery vendor.
Nature of Case: Taxable costs
Electronic Data Involved: ESI