In Abbott Point of Care, Inc. v. Epocal, Inc., No. 08-543 (N.D. Ala. Nov. 5, 2012), the court denied a Rule 54(b)(1) bill of costs request for approximately $340,000 in expenses related to maintaining e-discovery databases.  For its interpretation of Rule 54(b)(1) and the related 28 U.S.C. § 1920, the court relied on the Third Circuit’s decision in Race Tires America, Inc. v. Hoosier Racing Tire Corp., 674 F.3d 158 (3d Cir. 2012), which similarly denied an award of costs related to e-discovery.  The court explained that, although some federal courts have previously authorized e-discovery costs, “[s]ince the Third Circuit handed down its Race Tires America decision in March of [2012], almost all district courts considering the issue . . . have held that the costs of creating and maintaining an electronic discovery database are not recoverable under § 1920, expect insofar as the costs involve scanning documents or converting documents to an agreed-upon format[.]”