In multiple class actions brought by physicians against the nation’s largest HMOs, the American Medical Association, a non-party, was compelled to produce its annual reports regarding physicians’ income and medical practices and the underlying data for those reports. The defendants sought that material to defend against the plaintiffs’ allegations in the case. The AMA argued that it was entitled to the license fee it ordinarily charges for its reports, even though the district court, by protective order, limited the use of the data to litigation purposes. The U.S. Eleventh Circuit, in a case of first impression, considered the issue of whether the license fee should be recovered as “costs” under Rule 45(c)(3)(B), and determined that the district court did not abuse its discretion when it required the HMOs to pay the AMA only its production costs, because the AMA did not suffer a loss in the value of its property. Klay v. All Defendants, 425 F.3d 977 (11th Cir. 2005).