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Awarded Costs Constrained By Federal Rules And Regional Circuit Law

Client Alert | 1 min read | 02.09.06

In Summit Technology, Inc. v. Nidek Co., Ltd. (No. 05-1292; January 26, 2006), a Federal Circuit panel modifies the district court's award of costs, remanding the case to the lower court for entry of the modified award. At issue are the constraints of § 1920 of the Federal Rules of Civil Procedure dealing with taxation of specified costs, as applied under First Circuit law. The panel determines that video animations are not “exemplifications” as provided in 28 U.S.C. § 1920(4). Reviewing a variety of cases and Blacks Law Dictionary, which defines “exemplifications” as “[a]n official transcript of a public record, authenticated as true copy for use as evidence”, the panel determines that the First Circuit would adopt a narrow definition of “exemplifications” and refuse to allow recovery for video animations. The panel also reduces the lower court's award of photocopy and deposition costs as these portions of the award are not deemed properly supported by the evidentiary record.

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Client Alert | 4 min read | 08.21.25

FLSA Overtime Reporting and Withholding

The One Big Beautiful Bill Act (the Act), signed on July 4, 2025, allows a deduction from an individual’s personal tax return on Form 1040 for “qualified overtime compensation” as defined in new Code § 225. The amount that can be deducted from the employee’s return is capped at $12,500 with the maximum then adjusted down if the employee’s AGI exceeds certain limits. This deduction is permitted in 2025....