In U.S. v. Anthem, Inc., New York Magistrate Judge Katharine H. Parker found that “the government has not shown good cause to shift the burden to Anthem to pay for the additional security requested” to safeguard protected health information (PHI) of Anthem’s members, so she ordered the government to pay additional security costs to protect that PHI data – but “without prejudice to a renewed motion under Rule 26 to shift the costs of this enhanced security if Defendant engages in conduct that unreasonably extends discovery so as to increase the costs to Plaintiff.”

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