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Most electronic discovery costs STILL not recoverable by prevailing party unless analogous to “making copies” – Bagwe v. Sedgwick Claims Management Services, 11 CV 2450, 2015 WL 351244 (N.D.Ill. January 27, 2015). Bagwe v Sedgwick – 2015 WL 351244

Medina v. Catholic Health Initiatives (USDC CO, January 17, 2017) – $75,516.35 in data processing fees not recoverable by prevailing party because “language of the statute” (28 U.S.C. § 1920)…”is narrow and controlling” and only allows for recovery of “those ESI costs which actually constitute the making of copies”.

Also see, Can you be Compensated for Converting e-Discovery Files?

“Millions of dollars Are Up For Grabs Because Courts Can’t Figure Out if E-discovery Costs Are Recoverable”