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Breaking down exactly what costs are taxable under Title 28 of the U.S. Code Section 1920(4

The Country Vintner of North Carolina v. E. & J. Gallo Winery Inc clarified the scope of recoverable costs

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In The Country Vintner of North Carolina v. E. & J. Gallo Winery Inc., the prevailing party, Gallo, submitted a bill to the court under Title 28 of the U.S. Code Section 1920(4), seeking to recover its e-discovery costs. Gallo attempted to recoup $111,047.75, but the 4th Circuit only allowed it to recover $218.59, because many of the costs it asserted were not taxable under the statute. Below is a breakdown of the specific costs Gallo asserted, according to the 4th Circuit’s decision and whether they were or were not taxable:

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