Wayne M. Chiurazzi Law Inc. v. MRO CORPORATION, 27 A.3d 1272

MRO appeals a trial court order denying preliminary objections to Chiurazzi & Neely's second amended class action complaint.
Plaintiffs allege MRO charged more than the Medical Records Act (MRA) allowed for producing medical charts/records.
Key issue is whether 42 Pa.C.S. §6152(a)(2)(i) creates safe harbor rates for paper copies or merely a cap on actual expenses.
Liss & Marion holds paper copies are governed by the statute’s rates, with paper costs as default; non-paper copies not addressed.
The Superior Court holds paper-copy rates are safe harbor; CD-ROM/non-paper copies may lack safe harbor protection; remand for dismissal as to C&M's CD-ROM claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are safe harbor rates required for paper copies under §6152(a)(2)(i)?	Chiurazzi argues rates are not mandatory caps.	MRO argues rates are the cap for expenses.	Yes, paper-copy rates are safe harbor (not required to prove actual costs).
Does §6152(a)(2)(i) apply to non-paper copies (e.g., CD-ROM) for profit/subsection 6155(a)?	C&M argues non-paper costs can be charged under the Act.	MRO contends non-paper copies fall outside safe harbor.	Non-paper copies lack safe harbor protection; CD-ROM rates may require prior approval.
Can prior approval under §6152(a)(2)(i) validate the CD-ROM charge?	Charges exceed statutory per-page rates for CD-ROM copies.	Prior approval allows charging posted rates.	Prior approval validates CD-ROM charge if invoice advised and payment occurred.
Does the Act permit charging and remitting sales tax for reproductions?	Tax charged must be refundable; tax improper.	Sales tax may be collected; refunds pursued via DOR.	Tax issues are remanded; tax refunds pursued with Commonwealth per law.

Liss & Marion, P.C. v. Recordex Acquisition Corp., 603 Pa. 198, 983 A.2d 652 (Pa. 2009) (paper copies priced under MRA; counts for private action)