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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 | 5 min read | 06.01.26

California Court Upholds Insurer’s Duty to Defend After Covered Claim Is Dismissed

On April 30, 2026, the U.S. District Court for the Northern District of California issued a significant ruling in an insurance coverage dispute between a commercial general liability insurer and its policyholder. The decision addresses several critical issues in insurance law, including the scope and continuity of the duty to defend and the standard for insurer reimbursement of defense costs in mixed-claim actions. The court ruled largely in favor of the insured, SVO Building One, LLC ("SVO"), and the matter now heads toward settlement or trial on SVO's remaining counterclaims....

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