Court Awards Prevailing Party $4.6 Million in Costs for Litigation Database Creation

Lockheed Martin Idaho Techs. Co. v. Lockheed Martin Advanced Envtl. Sys., Inc., 2006 WL 2095876 (D. Idaho July 27, 2006)

In this diversity case, the federal district court awarded the prevailing party its costs under 28 U.S.C. § 1920(4) in three areas: (1) $4.6 million in costs for creating a litigation database; (2) $600,000 in costs for trial evidence presentation; and (3) $200,000 in costs for copies.

The court evaluated the request as follows:

Turning to the first category, the litigation database was necessary due to the extreme complexity of this case and the millions of documents that had to be organized. While the creation of the database is expensive, it is not unreasonably so, and it saved immense time for counsel who otherwise would have to sift through the documents by hand. Given these circumstances, the Court finds that these costs are recoverable under § 1920(4).

With regard to the trial evidence presentation costs, the Court required counsel to put the trial evidence in electronic format. It was important that the evidence presentation be efficient and of high quality. The Court cannot find these costs unreasonable. The Court will likewise approve the third category, the coping costs.