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Rimini Street, Inc. v. Oracle USA, Inc.
139 S. Ct. 873
| SCOTUS | 2019
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Background

  • Oracle sued Rimini Street (and its CEO) for copyright infringement and related state computer-access violations based on Rimini’s unlicensed use of Oracle software to provide third-party support.
  • A jury found Rimini liable and awarded Oracle $35.6M in copyright damages and $14.4M under state statutes; the district court later awarded attorney’s fees and costs and an additional $12.8M for litigation expenses (experts, e-discovery, jury consulting).
  • The Ninth Circuit affirmed the $12.8M award, allowing recovery of litigation expenses beyond the six categories listed in the federal costs statutes, relying on its precedent that §505’s term “full costs” is not limited to 28 U.S.C. §§1821 and 1920.
  • The Supreme Court granted certiorari to resolve a circuit split over whether “full costs” in 17 U.S.C. §505 authorizes awards beyond the costs enumerated in §§1821 and 1920.
  • The Supreme Court held that “full costs” means the costs defined by the general costs statutes (28 U.S.C. §§1821 and 1920) and does not authorize additional litigation expenses absent explicit statutory authority.

Issues

Issue Oracle's Argument Rimini's Argument Held
Whether “full costs” in 17 U.S.C. §505 authorizes courts to award litigation expenses beyond the categories in 28 U.S.C. §§1821 and 1920 “Full” expands “costs” to include broader litigation expenses (experts, e-discovery, jury consultants) and reflects historical meaning imported from English law “Costs” is defined by the federal costs statutes; absent explicit statutory authorization, non‑statutory litigation expenses cannot be awarded “Full costs” covers only the categories enumerated in §§1821 and 1920; additional litigation expenses require explicit statutory authority

Key Cases Cited

  • Crawford Fitting Co. v. J. T. Gibbons, Inc., 482 U.S. 437 (federal courts cannot award expert witness fees absent explicit statutory authority)
  • West Virginia Univ. Hospitals, Inc. v. Casey, 499 U.S. 83 (statutes awarding “costs” do not authorize expert fees without explicit direction)
  • Arlington Cent. Sch. Dist. Bd. of Ed. v. Murphy, 548 U.S. 291 (term “costs” is a term of art that generally excludes expert fees)
Read the full case

Case Details

Case Name: Rimini Street, Inc. v. Oracle USA, Inc.
Court Name: Supreme Court of the United States
Date Published: Mar 4, 2019
Citation: 139 S. Ct. 873
Docket Number: 17-1625
Court Abbreviation: SCOTUS