Race Tires America v. Hoosier Racing Tire Corp.

Citation. 674 F.3d 158 (3d Cir. 2012)

Brief Fact Summary.

Plaintiff sued Defendants for antitrust violations.

Synopsis of Rule of Law.

Rule 54(d) does not offer compensation for costs incurred by vendors for their services, other than converting and scanning documents.

Facts.

Race Tire America (Plaintiff) sued Hoosier and Dirt Motor Sports (Defendants) for antitrust violations. During the discovery, Defendants were required to produce searchable, electronic documents and videos. Both Defendants hired vendors to comply and properly format the requested documents and videos.

Issue.

May the Defendants recover, under Rule 54(d), all costs incurred by their vendors when compiling documents and videos for discovery?

Held.

No, the Defendants should not recover for all costs incurred by the vendors.

Discussion.

The Court concluded that, under Rule 54(d), the Defendants could not recover for all costs incurred during discovery. The Court  determined that Defendants could only recover the cost of converting the original documents into searchable documents and scanning the original documents to create searchable documents. For this, the Court awarded Defendants $20,083.51.