Rimini Street, Inc. v. Oracle USA, Inc.

Oracle sued Rimini Street for copyright infringement and computer fraud violations stemming from Rimini's third-party support of Oracle software. A jury awarded Oracle damages, and the district court awarded Oracle $12.8 million in “full costs” under the Copyright Act, which included non-taxable expenses such as e-discovery consultant fees. Rimini Street appealed, arguing that “full costs” should be confined to the specific categories listed in 28 U.S.C. §§ 1920 and 1821. The U.S. Supreme Court granted certiorari and, in a unanimous decision authored by Justice Kavanaugh on March 4, 2019, held that the term “full costs” in the Copyright Act is limited to the costs that courts may tax under the general federal cost statutes. The Court reversed the award of non-taxable expenses and remanded the case, significantly limiting recoverable litigation expenses in copyright disputes.

The U.S. Supreme Court unanimously reversed the Ninth Circuit's judgment, holding that “full costs” are limited to the costs defined in the general federal cost statutes, and remanded for further proceedings consistent with that opinion.

Whether the Copyright Act's allowance of “full costs” to a prevailing party under 17 U.S.C. § 505 authorizes a court to award expenses outside the six categories of taxable costs defined by 28 U.S.C. §§ 1920 and 1821, such as expert e-discovery consultant fees.

The decision sharply curtailed the ability of prevailing parties in copyright lawsuits to recover massive non-taxable litigation expenses, particularly those related to electronic discovery. This ruling altered cost-shifting strategies across the software industry, reduced financial risks for defendants in technology litigation, and reinforced a narrow interpretation of cost awards in federal intellectual property cases.