Steady State Imaging, LLC v. General Electric Company
- John Tunheim
- 0:17-cv-01048
- U.S. District Court · District of Minnesota
- 8
In Steady State Imaging v. General Electric, Judge Tunheim denied GE’s motion to remove transcript costs from Steady State’s $42,013.30 cost award.
Steady State Imaging, LLC retained its $42,013.30 cost judgment, and General Electric Company remained responsible for the awarded costs, including the daily and real-time transcript fees.
What happened
Steady State Imaging, LLC sued General Electric Company over promises involving magnetic resonance imaging technology. After a jury awarded Steady State $10 million, the Clerk awarded Steady State $42,013.30 in costs.
GE asked the court to remove $19,065.05 for daily trial transcripts and real-time transcripts, arguing they were obtained for convenience rather than necessity. The court found the transcripts necessary because the trial lasted twelve days, involved nearly 20 witnesses and complex testimony, and the transcripts were used during trial and in post-trial briefing.
Judge John R. Tunheim denied GE’s motion to review the Clerk’s action and allowed Steady State to recover the full cost award.
The detailed version
- Steady State Imaging, LLC v. General Electric Company · No. 0:17-cv-01048
- John Tunheim
- Feb. 6, 2024
Background
Steady State Imaging, LLC brought a contract dispute against General Electric Company. After a jury trial, the jury awarded Steady State $10 million on its promissory estoppel claim, and the court entered judgment against GE.
Steady State then submitted a bill of costs totaling $42,639.55 for deposition and trial transcripts. The Clerk issued a cost judgment in Steady State’s favor for $42,013.30. GE moved for the court to review that decision and sought to exclude $13,745.75 for daily trial transcripts and $5,319.30 for real-time transcripts.
Legal standard
Under Rule 54(d) of the Federal Rules of Civil Procedure and 28 U.S.C. § 1920(2), a prevailing party may recover the cost of transcripts that were necessarily obtained for use in the case. The losing party bears the burden of overcoming the presumption that permitted costs should be awarded.
Daily trial transcripts
The court concluded that the daily trial transcripts were necessarily obtained for use in the case. The trial lasted twelve days, involved testimony from nearly 20 witnesses, and included complex testimony. Steady State used the transcripts to prepare cross-examinations and its closing argument and to support post-trial briefing. Both parties also cited the daily transcripts extensively in their post-trial briefs. The court therefore taxed the full requested amount for the daily transcripts against GE.
Real-time transcripts
The court also concluded that the real-time transcripts were necessarily obtained for use in the case rather than primarily for the parties’ convenience. The court relied on the twelve-day trial and testimony concerning complicated magnetic resonance imaging technology. It therefore taxed the full requested amount for real-time transcripts against GE.
Disposition
The court denied GE’s Motion to Review Clerk’s Action. The full amount of the cost judgment remained awarded to Steady State.
Read the full 8-page opinion on CourtListener, the free public archive maintained by the Free Law Project.