Rimini Street Inc. v. Oracle USA, Inc.

The Copyright Act’s reference to “full costs” does not authorize a court to award litigation expenses beyond the six categories specified by Congress.

Respondent sued Petitioner for allegedly copying its software without a license while providing support services to Respondent’s customers. The Federal District Court in Nevada found that Petitioner infringed various copyrights and violated California and Nevada computer access statutes. In addition to damages received for copyright infringement and violation of state computer access statutes, the district court awarded Respondent attorney’s fees, costs, and litigation expenses. The relevant dispute on appeal revolved around the award of litigation expenses, which the Ninth Circuit affirmed on the ground that the Copyright Act permits the award of “full costs,” even though the Act does not include litigation expenses in its six categories of litigation expenses that qualify as costs. On review, the United States Supreme Court held that the Copyright Act’s reference to full costs does not authorize a court to award litigation expenses beyond the six categories specified by Congress. The Court reasoned that the Copyright Act’s cost statutes create a default rule establishing a clear baseline from which Congress can explicitly authorize awards of expenses. Citing precedent, the Court maintained adherence to the requirement of express authorization of awards beyond the baseline set out in the Copyright Act’s six categories of litigation expenses. REVERSED AND REMANDED.