Chancery Describes Limited Costs Included in Rule 54(d) Award

In Tanyous v. Happy Child World, Inc., (Del Ch., Dec. 19, 2008), the Chancery Court described the very limited scope of "costs" included under Rule 54(g) to the victor after trial. For example, "costs", as  that term is defined by the court,  in this context does not cover deposition transcripts or trial transcripts, nor does it include the cost of a translator. Two prior decisions of the court in this case were summarized here.