Rimini Street, Inc. v. Oracle USA, Inc.
The Supreme Court ruled that a copyright law letting judges award "full costs" only covers the standard categories of court costs listed in a general federal statute, not extra litigation expenses like expert witness fees or e-discovery.
The decision undoes a $12.8 million award to a software company for costs beyond that standard list, reinforcing a broader rule that courts can't award litigation expenses Congress hasn't specifically authorized.
How it got here: A federal trial court awarded Oracle $12.8 million in extra litigation expenses; the Ninth Circuit affirmed; Rimini asked the Supreme Court to review that ruling.
The Case in Depth
What happened
Oracle sued Rimini Street, a company that sells software maintenance services competing with Oracle, claiming Rimini copied Oracle's software without a license. A jury found Rimini liable for copyright infringement and awarded Oracle damages. The trial court then ordered Rimini to pay Oracle $12.8 million for litigation expenses such as expert witnesses, e-discovery, and jury consulting, on top of standard costs and attorney's fees.
The question before the Court
Could a company that won a copyright lawsuit collect $12.8 million for expenses like expert witnesses and e-discovery, beyond the usual court costs allowed by federal law?
Why it matters
Companies that win copyright lawsuits can no longer count on recovering expensive litigation costs like expert witness fees, e-discovery, or jury consulting unless Congress specifically allows it. This keeps copyright cost awards in line with most other federal lawsuits and limits how much winning parties can recoup from losers.
What changes now
The case goes back to the lower courts, which must recalculate the costs award to include only the six categories specified in the general federal costs statute, excluding the expert witness, e-discovery, and jury consulting expenses. The rest of the judgment, including the underlying damages award, is unaffected. This is a final merits ruling, not a temporary order.
How the Court got there
The legal reasoning, step by step
- The Court identified that a general federal statute, 28 U.S.C. §§1821 and 1920, lists exactly six categories of expenses that count as recoverable 'costs' in any federal lawsuit, forming a baseline that applies unless another law explicitly says otherwise.
- Applying its precedents in Crawford Fitting, Casey, and Arlington Central School District, the Court reasoned that a statute authorizing 'costs' cannot be read to cover extra expenses like expert witness fees unless it explicitly says so.
- The Court analyzed the word 'full' in the Copyright Act's phrase 'full costs' and concluded that 'full' is simply a word of quantity — meaning the complete amount of costs otherwise available — not a word that expands what counts as a cost in the first place.
- The Court rejected Oracle's argument that 'full costs' was a historical term of art importing broader English copyright-law meaning, finding no evidence that the phrase historically covered more than the applicable costs schedule and no case law supporting that broader reading between 1831 and 1976.
- The Court also rejected Oracle's argument that reading 'full' narrowly makes it meaningless surplusage, noting some redundancy in cost statutes is common and does not justify expanding the statute's scope.
- Because the Copyright Act does not explicitly authorize costs beyond the six categories in §§1821 and 1920, the $12.8 million award for expert witnesses, e-discovery, and jury consulting fell outside what 'full costs' could cover.
Doctrinal impact
Cases affected by this decision
Reaffirms Crawford Fitting Co. v. J. T. Gibbons, Inc. (482 U. S. 437)
Court relies on this case's rule that costs statutes require explicit authority to cover expenses beyond the standard six categories.
Reaffirms West Virginia Univ. Hospitals, Inc. v. Casey (499 U. S. 83)
Court leans on this case as confirming that 'costs' statutes need explicit authority to include expert witness fees.
Reaffirms Arlington Central School Dist. Bd. of Ed. v. Murphy (548 U. S. 291)
Court cites this case as reinforcing that costs statutes won't be read to include expert fees without explicit text.