In Dewey Beach Lions Club v. Longacre, et al., (Del. Ch., Oct. 11, 2006), read opinion here , the Chancery Court ruled on a post-trial "bill of costs" pursuant to Chancery Court Rule 54(d). This is the sort of practical letter opinion that I like to refer to as a useful reference tool for the business litigator’s "tool box". The court observed the limited scope of this rule, which does not cover attorneys’ fees, and the rule was distinguished from the costs that might be covered in light of a separate contractual basis for awarding costs.
Notable about this letter opinion on costs was the discussion of the costs incurred due to the requirement that all cases in Chancery Court must be eFiled, and all pleadings must be sent to the court via eFiling. Thus the costs incurred as a result of using the required vendor for eFiling, LexisNexis File & Serve, were taxed to the losing party to the extent that they were for required for eFiling, but the prevailing party was careful not to request reimbursement for services by LexisNexis that were not required, such as a case history report.