In Colosi v. Jones Lang LaSalle Americas, Inc., No. 11-cv-824, 2015 WL 1186765 (6th Cir. Mar. 17, 2015), the Sixth Circuit held that 28 U.S.C. § 1920 authorizes a broader recovery of e-discovery costs than the Third Circuit previously found in an influential opinion, Race Tires America, Inc. v. Hoosier Racing Tire Corp., 674 F.3d 158 (3d Cir. 2012).  In Race Tires, the Third Circuit held that most e-discovery costs are not recoverable under § 1920 because they are not akin to “making copies” or the other types of costs that are specified in the statute.  In Colosi, the Sixth Circuit held that the Race Tires interpretation was “overly restrictive” and inconsistent with a 2008 amendment to § 1920, which changed the phrase “making copies of papers” to “making copies of any materials.”  In particular, the Sixth Circuit held that making an electronic image of a hard drive is a recoverable cost under § 1920 because it “falls squarely within the definition of ‘copy.’”  The Sixth Circuit stressed that “courts have long understood that the phrase ‘making copies’ fairly includes the production of imitations in a medium or format different than the original.”