Camesi v. Univ. of Pittsburgh Med. Ctr., —Fed. Appx.—, 2016 WL 7402982 (3d Cir. Mar. 21, 2016)

Key Insight: Court indicated that it was “not readily apparent what ESI activities the charges at issue cover[ed], or how th[ose] activities constitute[d] either of the two applicable types of taxable costs identified in Race Tires Amer., Inc. v. Hoosier Racing Tire, Corp., 674 F.3d 158 (3d Cir. 2012) and, following an extensive discussion of the reasoning and findings in Race Tire, indicated that ?the highly technical nature of the services simply does not exempt parties who seek to recover their electronic discovery costs under ?1920(4) from showing that the costs fall within the subsection?s limited allowance for ?the cost of making copies of any materials?? and vacated and remanded the case, suggesting that the court consider an evidentiary hearing or taking additional evidence to make its decision

Nature of Case: Fair Labor Standards Act

Electronic Data Involved: Taxable Costs