Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Filing 1401

PROPOSED BILL OF COSTS filed by J.C. Penney Corporation, Inc.. (Attachments: # 1 Exhibit 1 - Declaration of Christopher M. Joe, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8 - Part 1, # 9 Exhibit 8 - Part 2)(Joe, Christopher)

Exhibit 6
Exemplification and Copies (JCP)
Date of Invoice

Description

Bates JCPBill

Amount

Breakdown

Agreed to by Eolas

Eolas Counter-Proposal

Legal Network
Uploading Eolas document
production to internal e-room
3/23/2010
for electronic document review
on invoice 4372-2010 ($202.50)

105

$202.50

Eolas Doc Prod Ediscovery
4.5 hours of tech time at $45/hour = $202.50

NO

Uploading Eolas document
production to internal e-room
3/30/2010
for electronic document review
on invoice 4382-2010 ($562.50)

104

$202.50

Eolas Doc Prod Ediscovery
12.5 hours of tech time at $45/hour = $562.50

NO

Subtotal:

4/19/2010
4/28/2010
5/17/2010

7/19/2010
8/10/2010
8/31/2010

Duplication of production CDs
on GT Imaging invoice 201004192367
Photocopies on GT invoice
2664722
Duplication of production CDs
on GT Imaging invoice 201005172367
Duplication of production CDs
on GT Imaging invoice 201007192367
Copies for production on GT
invoice 2810809
Color copies on GT invoice
2813985

$405.00

$0.00
No Claim

$0.00

Greenberg Traurig Imaging
8

$60.00

Copying
4 CDs at $15/CD

NO

5

$37.10

Copying
4 CDs at $15/CD

NO

9

$60.00

Copying
4 CDs at $15/CD

NO

24

$195.00

Copying
13 CDs at $15/CD

NO

31

$0.40

Coyping

NO

29

$140.00

Coyping

NO

9/29/2010

Concordance FYI hosting on GT
Imaging invoice 20100927-2367

40

$40.00

Ediscovery Hosting

NO

10/29/2010

Concordance FYI hosting on GT
Imaging invoice 20101027-2367

92

$40.00

Ediscovery Hosting

NO

48

$60.00

Coyping
4 CDs at $15/CD

NO

81

$50.00

Ediscovery Hosting

NO

84

$120.00

Copying
8 CDs at $15/CD

NO

Duplication of production CDs
12/6/2010 on GT Imaging invoice 201012062520
2/28/2011

Concordance FYI hosting on GT
Imaging invoice 20110228-2367

Duplication of production CDs
3/1/2011 on GT Imaging invoice 201103012520

Exemplification and Copy Fees

1 of 9

Exhibit 6

3/29/2011

Concordance FYI hosting on GT
Imaging invoice 20110329-2367

96

Ediscovery Hosting

$852.50

Subtotal:

$50.00

$852.50
Copies - $672.50
Ediscovery Hosting - $180.00
Keystone Document Discovery

Copying of documents for
6/12/2010 production on Keystone invoice
17449

18-20

Subtotal:

$111.84
$111.84

Summit Reprographics
OCR Tiff imaging/scanning and
CD burn for document
7/30/2010 production on Summit invoice
68264 [this is the amount that
was billed to JCP]
Scan OCR and CD burn of
10/29/2010 document production on
Summit invoice 69371
Scan OCR and CD burn of
document production on
12/31/2010 Summit invoice 70043 [this is
the amount that was billed to
JCP]
Subtotal:

35

42-43

69

$1,181.95

$237.55

Doc Prod Copying
620 copies = $74.40
110 tabs = $27.50
sales tax = $9.94
$101.90
Copies - $101.90

Doc Prod Ediscovery
1032 scan = $123.84
144 tiff = $11.52
1176 OCR = $35.28
10,414 tiff = $833.12
1 CD burn = $15.00
1 DVD burn = $20.00
sales tax $105.00
Doc Prod Ediscovery
1343 scan/ocr = $201.45
1 CD burn = $15.00
sales tax = $21.10

NO
$0.00

NO
$0.00

$73.47

$201.45

Doc Prod Ediscovery
88 scan/ocr/bates = $13.20
1 CD burn = $15.00
sales tax = $2.75

$13.20

$1,283.41

$30.95

NO INDICATION ON INVOICE
WHAT'S FOR EACH OF FL, RAC, JCP

$288.12

$1,450.45

NO INDICATION ON INVOICE
WHAT'S FOR EACH OF FL, RAC, JCP

Document Production Ediscovery - $1,283.41
Teris
Endorsing document
production, OCR, Tiff document
production and hosting on Teris
7/30/2010 invoice 33358 (JCP-Eolas 0000141 browser reports) [$603.45
the amount that was billed to
JCP]

36-38

Doc Production Ediscovery
369 bates = $3.69
369 convert PDF to tiff = $14.76
369 ocr = $14.76
$603.45
3 hours tech time to load to database = $525
41 bates = $0.41
convert color natives to jpg/PDF/tiff color = $1.30
1 hour tech time to process Excel load to database
= $175.00

Exemplification and Copy Fees

$34.96

NO INDICATION ON INVOICE
WHAT'S FOR EACH OF FL, RAC, JCP

2 of 9

Exhibit 6

Prcoessing Eolas document
8/31/2010 production and database
hosting on Teris invoice 33688

64-65

Endorsing document
production, OCR, Tiff document
9/30/2010
production and hosting on Teris
invoice 34171

77

Database hosting on Teris
10/29/2010
invoice 34628

OCR Tiff imaging/scanning, DVD
burn and hosting of document
10/29/2010
production on Teris invoice
34627

10/29/2010

Database hosting on Teris
invoice 34775

Doc Prod Ediscovery and Hosting
3 hours tech time to prepare, load, setup database
for Eolas production UCPROD001.rar, UCPRA_0001.rar = $525.00
6 hours tech time to create database, upload files,
match fields from 8/16/10 Eolas hard drive
production = $1050.00
$9,572.50
FedEx to return hard drive = $25.60
monthly database hosting fee at $20/GB/month =
$5186.00
3 logins = $297.00
incremental additional loading of data at $10/GB =
$2488.90

NO

$576.52

Doc Pro Ediscovery and Hosting

NO

$48.42

Ediscovery Hosting
monthly database hosting fee at $35/GB/month =
$15.75
monthly login fee at $99/user/month = $32.67

NO

54

$4,838.11

Doc Pro Ediscovery and Hosting
file conversion to tiff with searchable text,
metadata and native link at $650/GB = $3789.50
874 ocr = $34.96
1 DVD burn = $45.00
monthly database hosting fee at $35/month =
$281.05
monthly login fee = $329.67
sales tax = $357.93

$34.96

55

$430.50

Ediscovery Hosting
monthly database hosting fee at $5/GB/month =
$430.50

NO

47

Exemplification and Copy Fees

NOT AN INVOICE FROM VENDOR

WHAT IS JCPCTRL RANGE? (TIFF
3789.50 + OCR 34.96 = 3824.46)

3 of 9

Exhibit 6

Endorsing document
production, OCR, Tiff, CD burn,
11/30/2010 hosting of document production
and hosting on Teris invoice
34931 (JCP-Eolas42-46250)

56

$4,579.88

12/31/2010

Database hosting on Teris
invoice 35419

63

$478.92

1/31/2011

Database hosting on Teris
invoice 35842

245

$1,041.57

2/28/2011

Database hosting on Teris
invoice 36311

85

$611.07

3/31/2011

Concordance storage on Teris
invoice 36756

93

$1,291.50

3/31/2011

Database hosting on Teris
invoice 36764

94

$405.15

Endorsing document
production, OCR, Tiff, and hard
4/30/2011 drive burn for document
production and hosting on Teris
invoice 37056

99-100

Doc Pro Ediscovery and Hosting
bates JCP42-69250 = $692.09
ocr = $2076.27
2 tech hours to create dat file and load to database
= $350.00
0.75 hours to create production sets = $150.00
monthly database hosting fee at $35/GB/month =
$281.40
monthly login = $329.67
monthly database hosting fee at $5/GB/month =
$430.50
sales tax $269.95
Ediscovery Hosting
monthly database hosting fee at $35/GB/month
$15.75
monthly login fee = $32.67
monthly database hosting fee at $5/GB/month =
$430.50
Ediscovery Hosting
monthly database hosting fee at $35/GB/month =
$281.40
monthly login fee = $329.67
monthly database hosting fee at $5/GB/month =
$430.50
Ediscovery Hosting
monthly database hosting fee at $35/GB/month =
$261.40
monthly user login fee = $329.67
Ediscovery Hosting
monthly database storage at $5/GB/month =
$1291.50
Ediscovery Hosting
monthly database hosting fee at $35/GB/month =
$281.40
monthly login fee = $123.75

Doc Pro Ediscovery and Hosting
23 convert PDF to tiff for JCP presentation S7
023609 = $0.92
bates = $0.23
ocr = $1.84
$976.92 1 hour tech time at $175/hour to prepare data and
load to FYI Concordance = $175.00
monthly database hosting = $281.40
monthly login = $123.75
1 hour tech time to export to hard drive = $175.00
1 hard drive = $200.00

Exemplification and Copy Fees

$2,076.27

BATES 692.09 + OCR 2076.27 =
2768.36

NO

NO

NO

NO

NO

$1.84

TIFF 0.92 + BATES 0.23 + OCR 1.84
= 2.99

4 of 9

Exhibit 6

Hosting of document
4/30/2011 production on Teris invoice
37076

244

Subtotal:

Blowbacks of Eolas document
4/6/2011 production on eXact invoice
4620
Subtotal:

9/10/2010

4/25/2011

5/13/2012

6/27/2011

Copy Eolas hard drive
productions on A-Legal invoice
109024
Blowbacks of JCP document
production made at request of
Matt Rappaport for use at
deposition of Coultas and
Wilson on A-Legal invoice
11004099
DVD and CD burn for document
production on A-Legal invoice
11005205
Blowbacks of and DVD burn for
document production on ALegal invoice 11006237
Subtotal:

$709.66

$26,164.17

95

$327.35
$327.35

Ediscovery Hosting
monthly database hosting at $5/GB/month =
$1291.50
2.5 hours tech time to export database to hard
drive = $437.50
imaging services = $400.00
$22,882.70
Document Production Ediscovery - $7274.73
Ediscovery Hosting - $15,607.97
eXact Legal Copy Services
Printing Eolas Production
3780 blowbacks = $302.40
sales tax = $24.95
$302.40
Copies - $302.40

NO

$2,148.03

NO
$0.00

A-Legal

76

Eolas Doc Prod Copies
$186.73 copy 2 hard drives of Eolas' document production =
$186.73

NO

114

Doc Prod Copies at McKool's request
5598 blowbacks requested by Eolas for use at
$606.57
deposition = $447.84
0.75 hours tech time to format excel spreadsheets
= $150

NO

144

$649.50

127

$1,556.64
$2,999.44

Doc Prod Copies
13 dvd duplication = $520.00
4 cd duplication = $80
Doc Prod Copies
12780 blowbacks = $1278.00
dvd duplication = $160.00
$2,672.57
Copies - $2,672.57

NO

NO
$0.00

KTS Litigation Support Services

Exemplification and Copy Fees

5 of 9

Exhibit 6

2/8/2012

Copy set of trial exhibits on KTS
invoice 9031

187

Subtotal:

$1,171.73

$1,171.73

Trial Exhibits
6315 copying = $631.50
20% discount = -$126.30
73 color copies = $69.35
53 folders and assembly = $87.45
15% discount = -$13.12
2 redropes = $11.00
117 tab dividers = $193.05
5 3-ring binders = $90.00
10 CD burns = $275.00
55% discount = -$151.25
1 DVD burn = $35.00
55% discount = -$19.25
sales tax = $89.30
$1,082.43
Copies of Trial Exhibits - $1,082.43

Yes - limited solely to
$505.20 + 69.35 (for
copying)

Trial Exhibit Set

$574.55

SwayLaw LLC

Endorsing trial exhibits and
preparing electronic set of
2/17/2012
exhibits on SwayLaw invoice
1293

Subtotal:

192

Trial Exhibits
141 stickering of PDF trial exhibits with text
searchable stickers $133.95
0.8 hours tech time to place and adjust exhibit
stickers = $76.00
0.7 hours tech time to correct rotation of exhibit
pages = $66.60
88510 create text searchable PDFs of exhibits and
$968.16
ocr = $4425.50
adjustment to account for previously ocr'ed
exhibits = -$4304.90
2412 labeling each page with page numbers =
$48.24
3 hours tech time to label page numbers = $300.00
tech time for processing joint trial exhibits =
$222.87

$968.16

$302.69
Copies of Trial Exhibits - $302.69

No

$0.00

Inventus

Exemplification and Copy Fees

6 of 9

Exhibit 6

Creation of production CDs and
hosting on Inventus invoice
4/30/2011
DAL3554 (JCP-Eolas2 081568178)

Hard drive imaging for
ediscovery production
requested by Eolas from JCP
5/31/2011 witnesses, creation of
production CDs, OCR and
hosting on Inventus invoice
DAL3624 (JCP-Eolas2 81497)

Hard drive imaging for
ediscovery production
6/7/2011 requested by Eolas from JCP
witnesses on Inventus invoice
DAL3788

203

$991.29

Doc Prod Ediscovery
FYI load fee = $18.00
FYI monthly hosting = $165.60
FYI user fee = $100
2.5 hours tech time for project management
searches = $500
975 convert documents to PDF for production =
$29.25
48 processing of native documents for production
= $4.80
3 CD burns = $75.00
shipping = $25.00
sales tax $73.64

204

Doc Prod Ediscovery
FYI load fee = $334.50
FYI monthly hosting = $667.35
FYI user setup = $100.00
FYI user fee = $200.00
4 hours project management tech time for
searches = $800.00
4 hours processing tech time for tiff delivery =
$3000.00
1 hour processing tech time for native document
production = $150.00
$15,344.08
1 hour tech time for filtering = $150.00
73326 bates = $733.26
73326 ocr = $2199.78
7.5 hours tech time for hard drive imaging, live
data acquisition, expoert date from image, filtering
and expoerting for processing = $2625.00
6 cd burn = $150.00
2 DVD burn = $90.00
73326 tiff processing = $2199.78
3 hours tech time for tiffing = $525.00
sales tax = $1169.41

205

Doc Prod Ediscovery
16 hours project management to image to hard
drive = $1200.00
USB hard drive = $250.00
sales tax $119.63

$1,569.63

Exemplification and Copy Fees

NO

$2,199.78

TIFF AND NATIVE? (TIFF 5199.78 +
NATIVE 400.00 + BATES 733.26 +
OCR 2199.78 = 8532.82) We will
agree to costs for load files/OCR
associated w/ native production if
you can identify.

NO

7 of 9

Exhibit 6

Creation of production CDs and
6/30/2011 hosting on Inventus invoice
DAL4004

Hosting and endorsing
7/31/2011 document production on
Inventus invoice 4110

Hosting, endorsing document
production, and creation of
8/31/2011
production CD on Inventus
invoice 4301

Doc Prod Ediscovery
FYI load fee = $23.40
FYI monthly hosting = $702.45
FYI user fee = 702.45
9 hours tech time for project management
searches $1800.00
tiff delivery - $750
5654 bates = $56.54
OCR - $69.90
Relativity near line storate of source data =
$1661.20
1 DVD burn = $50.00
8 CD burn = $200.00
1 hard drive = $100.00
146,640 PDF conversion = $1466.40
sales tax = $584.09

206

$7,663.98

207

Doc Prod Ediscovery
FYI hosting = $702.90
FYI user fee = $200.00
1 hour project management for searches = $200.00
$3,009.24
632 bates = $6.32
316 convert to tiff = $9.48
data storage = $1661.20
sales tax = $229.34

208

$3,370.60

9/30/2011

Hosting production on Inventus
invoice 4590

209

$2,992.14

10/31/2011

Hosting production on Inventus
invoice 4935

210

$2,775.64

Doc Prod Ediscovery
FYI monthly hosting = $702.90
FYI user fee = $200.00
2 hours project management = $400.00
49 bates = $0.49
49 convert to tiff = $1.47
49 ocr = $1.47
near line data storage = $1661.20
4 CD burn = $100.00
shipping = $50.00
sales tax = $253.07
Ediscovery Hosting
FYI monthly hosting = $702.90
FYI user fee = $200.00
1 hour project management = $200.00
near line storage = $1661.20
sales tax $228.04
Ediscovery Hosting
FYI monthly hosting = $702.90
FYI user fee = $100.00
near line storage = $1661.20
sales tax = $211.54

Exemplification and Copy Fees

$69.90

TIFF 750.00 + BATES 56.54 + OCR
69.90 = 876.44

NO

TIFF 9.48 + BATES 6.32 = 15.80

$1.47

TIFF 1.47 + BATES 0.49 + OCR 1.47
= 3.43

NO

NO

8 of 9

Exhibit 6

11/30/2011

Hosting production on Inventus
invoice 5139

211

$2,992.14

12/31/2011

Hosting production on Inventus
invoice 5463

212

$2,775.64

Subtotal:

$43,484.38

Ediscovery Hosting
FYI monthly hosting = $702.90
FYI user fee = $200.00
near line storage = $1661.20
1 hour project management = $200.00
Ediscovery Hosting
FYI monthly hosting = $702.90
FYI user fee = $200.00
near line storage = $1661.20
sales tax $211.54
$28,403.49

NO

NO

$2,271.15

Ediscovery Hosting - $19,959.55
Document Production Ediscovery - $8,193.94
Copies - $250.00
Total:

$77,935.02

$57,884.09

Exemplification and Copy Fees

$5,281.85

9 of 9