In a recent U.S. District Court case, it was determined that copying costs must be reasonably related to the litigation, and such costs for copies must not be excessive. In Mars Area Sch. Dist. v. C. L., No. 2:14-CV-1728, 2015 WL 8207463, at *8 (W.D. Pa. Dec. 7, 2015), the Court ruled in favor of the School District on the basis that the opposing party did not provide an explanation of why so many copies were necessary. The Appellee in this case sought reimbursement for 4,445 copies at a rate of $0.20 per page. The argument was that the copies were exhibits needed for hearings. However, only 70 pages of exhibits were submitted for the hearing. No further explanation of why the remaining copies were needed was provided. Therefore, the Court concluded ‘[w]ithout any cogent explanation having been provided . . . the number of copies is excessive,” and reduced the quantity for reimbursement to 1,000 copies.
Also at issue was the cost per page for which the Appellee was to be reimbursed. The Court, in its findings, stated “[m]ost courts to consider the issue have found that a rate of 10 to 15 cents per copy is appropriate,” and further stated that the “Third Circuit’s local rules only allow for assessing copying costs at 10 cents per page and ‘Fed Ex/Kinko’s charges less than 7 cents per page for large volume copying.’” In keeping with this rationale the Court found a rate of $0.15 per page reasonable and not the $0.20 per page reimbursement that was sought.