Kendall F. Svengalis, Legal Information Buyer’s Guide and Reference Manual 147-52 (2005)
Choosing Between Lexis and Westlaw
For some time after the introduction of Lexis and Westlaw, it was common for reviewers to draw comparisons based on the size and scope of their respective databases. Prospective subscribers were often persuaded to adopt one system or the other because the case law for their jurisdiction was more extensive, for example. For several years, Lexis was perceived as having an advantage because it included the text of unpublished opinions. As time passed the subject matter and chronological coverage of both systems grew so extensive that such comparisons were largely futile. If one vendor added a database which gave it a perceived advantage, the other vendor followed suit or jumped ahead in another area. This competitive process of leapfrogging has helped ensure that both Lexis and Westlaw have databases so large that very few subscribers will ever begin to tap their full potential. As the databases reached a rough parity in terms of content, Westlaw's synopsis, headnote, and key number searching, in addition to full text, provided it with an advantage over Lexis in the area of case law research. Since LexisNexis has introduced such enhancements as Lexis Search Advisor, core terms, and case summaries, however, the playing field has been considerably leveled.
For those who wish to know which of the two systems is best, I can only say that "it depends." Each system has its strengths and both share the weaknesses of online information retrieval outlined by Blair and Maron. In fact, there are distinct advantages to having both systems if yours is a firm which expects to conduct considerable online research. In addition to rough parity in terms of database coverage, both Lexis and Westlaw provide users with the ability to conduct both Boolean and natural language searching. The one major advantage Westlaw enjoyed was an outgrowth of its dominance in the area of print court reporters and finding tools, although this advantage in narrowing as Lexis adds more case summaries and core terms to the cases in its database. The Lexis core terms are a useful indication of case content once a case has been retrieved, but they do not add terms which are not already in the opinions themselves, as the West headnotes and synopses do. However, this comparative advantage applies primarily to case law and does not necessarily impact research in statutory or regulatory law or in the hundreds of other areas, both legal and non-legal, for which both services provide extensive coverage. The Lexis Search Advisor, as stated above, also helps narrow the research advantage formerly held by Westlaw in the case law arena.
For a time, Lexis held the edge in terms of cost, largely due to its transactional pricing. This advantage undoubtedly increased with Lexis's elimination of telecommunications and connect charges. Earlier studies revealed that LEXIS was the cheaper of the two services most of the time. The advantage was particularly marked in the case of lengthy search sessions (30-60 minutes). Westlaw was the cheaper service for shorter search sessions. Since that time, Westlaw and Lexis have both introduced transactional pricing and fixed-. rate plans tailored for the small law office, rendering these earlier cost comparisons obsolete. These developments have sharply narrowed the cost differential between these two major online services.
With, arguably, a rough parity between the editorial content and pricing of the two citator services, Shepard's and KeyCite, offered by Lexis and Westlaw, Lexis comes out ahead because an All Jurisdictional Shepard's subscription allows the user to access and print any case for which he or she has a cite or to which he or she can link from a list of citing references. By contrast, a KeyCite user on Westlaw can only gain "free" access to documents which fall within his or her Westlaw PRO plan. For all others, there is a per document charge.
Fixed-Rate Contracts for CALR
Despite the fact that Lexis and Westlaw have been strong competitors for nearly 30 years, little information exists regarding fixed-rate contracts for online services in large law firms and other institutions. Yet, in an era when clients have begun to question charges for online computer services and law firms are forced to treat them as a part of overhead, renewed attention is being devoted to contractual arrangements under which online costs are fixed. While many large firms have entered into such contracts, the terms of such agreements are usually kept confidential.
Law firms contemplating a subscription to one of the major online legal research systems would do best to secure proposals from both Lexis and Westlaw and play one off against the other to secure the best deal. Firms entering into such contracts should, nevertheless, be warned to control costs since higher usage will be factored into the next fixed-rate proposal and/or contract. Thus, the window of opportunity which may exist for a time as the lawyers in your firm take advantage of the fixed-rate contract to increase usage will be closed when the next contract is negotiated at a higher price level. In this regard, a VersusLaw subscription can serve as an excellent means of controlling usage with one of the two major online vendors. Firms should also resist contractual provisions which prevent disclosure of the terms of the fixed-rate contract. This practice is a reflection of the heretofore limited number of CALR vendors. More recent entrants into the field, such as VersusLaw, Loislaw.com and Fastcase, have completely transparent pricing options, a development which may induce the major CALR providers to discontinue their efforts to keep customers from freely sharing contractual terms.
One strategy which holds the greatest promise of holding down usage and costs for Westlaw and LEXIS-NEXIS is a subscription to VersusLaw which permits unlimited searching for a flat annual fee. Law firms which can resist the urge to use Westlaw or LexisNexis for many of their common searches, or for such comforting, but unnecessary, features as dual-column printing, will be in the best position to negotiate lower flat-rate contracts when these are up for renewal. Establishing protocols for accessing the various online services can help control the often lazy research habits of recent law school graduates who enjoyed virtually unlimited access to Westlaw and LexisNexis in a rarefied world devoid of real world financial constraints.
Alternative CALR Services
Casemaker
One of the alternative computer-assisted legal research services which has had a significant impact on computer-assisted legal research in some markets is Casemaker. Developed by Cincinnati lawyer Joseph Shea and the Lawriter Corporation, an electronic legal publisher, Casemaker began as a highly popular CD-ROM product marketed to Ohio attorneys in 1988. Joining forces with the Ohio State Bar Association, Casemaker moved to the Internet in 1998, offering Ohio State Bar members access to a complete library of Ohio legal materials. Since that time, additional state bar associations have approached Casemaker to join the Casemaker consortium. As of April, 2005, more than 20 state bar associations have done so, including all six New England states, as well as Idaho, Indiana, Michigan, Nebraska, North Carolina, Ohio, Oregon, South Carolina, Texas, Utah, and Washington. The Casemaker database also includes decisions of the United States Supreme Court back to 1936 and more limited coverage of decisions of federal appellate courts. It has already made a significant impact in Ohio, where bar association surveys have shown it to be the most heavily user CALR service. Casemaker is only available to members of the participating bar associations. We include Casemaker among the leading alternative CALR services because it has become the default CALR service for most bar members in the above mentioned states.
Content for each of the states currently in the consortium features the full range of primary law, including case law, applicable federal court decisions, state codes and constitutions, session laws, regulations, rules of professional conduct, attorney general opinions, workers' compensation opinions, bar journals, and more. Moreover, Casemaker's coverage is not limited to the highest appellate courts and local federal courts, but extends to the courts of appeals, and some trial courts. Content is selected in consultation with each state bar association and, as such, it reflects the specific needs and desires of the practitioners in those states. The Casemaker search engine employs an intuitive technology which includes both Boolean and natural language protocols, a Thesaurus function, and a case history citator. It is simple to navigate and allows users to conduct in each database.
Casemaker's success is a striking indication of the need for low-cost CALR by attorneys across the country. Ohio State Bar Association surveys have revealed that utilization of Casemaker now exceeds that of any other computer-assisted legal research service. And it is not difficult to understand why. Casemaker is rapidly becoming one of the most popular benefits of state bar association membership. In states with a unified (mandatory) bar, Casemaker is being made available to every bar member. In states with a voluntary bar, Casemaker has become the single greatest factor driving the enrollment of new members. With thousands of bar members using Casemaker, the per member cost averages a mere $20 per year. The strength of numbers has made Casemaker into a major success story for users of computer-assisted legal research in some states.
Casemaker will no doubt have a significant impact upon the legal research habits of lawyers in states whose bar associations are part of the consortium. The major question, however, is whether Casemaker can develop a national database of primary and secondary materials and a cross-file searching capability which will make it a major player at the national level. At present, each state's database must be searched independently. Moreover, there is no one site on the Internet where comprehensive information on Casemaker's database coverage may be found. Users are dependent upon the information supplied by the individual bar association sites regarding coverage of the other state sites. There are early indications that some state bar associations are not interested in joining the consortium, a factor which will hinder the creation of a complete national database unless its parent company deigns to add those states on its own initiative and expense. Nevertheless, Casemaker will no doubt have a significant impact on the market for computer-assisted legal research in those states whose bar associations do choose to participate, while restricting the ability of Westlaw and LexisNexis to expand in those states.
Fastcase
The most recent entrant into the growing field of CALR providers is Fastcase, an Arlington, VA-based legal research system with an impressive combination of features, including an intuitive search engine, unique navigational tools, and a substantial body of primary law, providing access top over 5.5 million documents. Unlike other alternative CALR providers, however, Fastcase includes such unique search tools as Authority Check, a citator-like service that not only locates other cases citing your authority, but also provides the text surrounding the citation being checked. A Briefcase feature allows the researcher to save documents for future use and store up to 18 recent queries. In addition, search results can be sorted according to various criteria of relevance, including most cited within search results, most cited generally, date, and court hierarchy. Search results can also be \viewed by title only, by the first paragraph, or by the most relevant paragraph.
Searching on Fastcase is performed using either standard Boolean operators or natural language and pattern searching (which employs expanded versions and variations of search terms). The format and design are professional and aesthetically pleasing in appearance. West and official pagination are provided when available. Other features include dual column printing, hyperlinked case citations, and multiple citation lookup and extraction. The primary law databases include more than 5.5 million documents, including state and federal cases (most dating back to 1950). Statutes and administrative regulations are provided by linking to official government web sites, but searching is conducted by using the Fastcase search engine. Decisions of the U.S. Supreme Court date back to volume one of the United States Reports (i.e. 1754). Documentation and customer support are provided via tutorials, search tips, frequently asked questions (FAQ), and E-mail. Additional help is provided by means of online chat.
Fastcase offers the following subscription plans:
Premium Plan - $995 per year for a solo practitioner. 
Annual subscription to the full national law library, including federal and 50-state caselaw, statutes, and regulations, including federal district courts, bankruptcy and tax courts. 
National Appellate-Only Plan - $695 per year for a solo practitioner.
Comprehensive federal and 50-state database of appellate caselaw, statutes and regulations.
Pricing for larger firms follows a banded pricing model similar in structure to that employed by LexisNexis and Westlaw. Thus, Premium Plan pricing for 2 attorneys is $1,745.00 per year; 3-5 attorneys $2,495.00 per year; 6-10 attorneys $3,995.00 per year, and so forth. Pricing for larger firms may be negotiated. Special promotions may also be offered at various times. A number of large firms are using Fastcase as a means of reducing costs for Lexis and Westlaw. A review of Fastcase by T.R. Halvorson appearing in the August 1, 2002 issue of llrx.com, is located at: http://www.llrx.com/features/idm_fastcase.htm
Loislaw.com
Loislaw.com (formerly LOIS) is an Arkansas-based electronic publisher of comprehensive libraries of state and federal primary law on the Internet and CD-ROM. Founded by practicing attorney Kyle D. Parker in 1987 as a response to the absence of a low-cost alternative to the major online legal services, LOIS was the first company to develop and market a comprehensive library of primary law on CD-ROM: CaseBase-Arkansas (1989). LOIS went on to develop state CD-ROM products for Connecticut, Georgia, Louisiana, Massachusetts, Missouri, Nebraska, North Carolina, Oklahoma, Rhode Island, South Carolina, Wisconsin and other states, as well as CD-ROM libraries containing decisions of the U.S. Supreme Court and U.S. Courts of Appeals. In 1996, LOIS unveiled a Web site providing up-to-date coverage of the same state and federal primary law previously available on CD-ROM. Its law libraries of state materials typically include Supreme Court and Appeals Court decisions, statutes, session laws, attorney general opinions, administrative regulations, ethics opinions, and court rules. U.S. Supreme Court decisions are available back to 1790 and Court of Appeals decisions back to 1972. Partnerships with a number of state bar associations have resulted in the inclusion of state bar CLE materials in such states as Arkansas, Indiana, Massachusetts, Missouri and Wisconsin. In 2000, Loislaw.com achieved it goal of making available comprehensive libraries for all fifty states and the federal government.
Since its introduction in 1987, LOIS has done much to stimulate competition in the online legal research market. With its low-cost CD-ROM and Internet products, Loislaw.com has forced both Westlaw and LexisNexis to address the needs of the attorney in the smaller law office who had previously been paying high hourly costs for repeated access to the law of his or her jurisdiction. The appearance of LOIS's state CD-ROM products forced West, which had initially resisted competing against its print products and Westlaw service, to develop and market its own line of state and federal CD-ROM products. LOIS was the first vendor to abandon the upfront licensing fees for CD-ROM products and the first to sell CD-ROMs without a built-in time expiration feature. It was also the first legal CD-ROM vendor to sell individual CD-ROMs without requiring the purchase of a subscription (although subsequently abandoned), and the first to offer a no-cost online uplink from its CD-ROM products.
Moving to the Web
Loislaw.com unveiled its Web-based product in 1996. By the first quarter of 2000, it was providing complete law libraries for all 50 states, decisions of the U.S. Courts of Appeals from 1971 to date, decisions of the U.S. Supreme Court from 1899 to date, the United States Code, Code of Federal Regulations, and Federal Register. In the process it also shifted its product focus from CD-ROM to the Internet. Its National Collection provides a comprehensive database of state and federal materials and is an alternative for attorneys who desire low-cost access to the primary law of all state and federal jurisdictions. For the attorney interested in the law of more than one state, the National Collection has become an alternative, priced at $3,000 per year, or about the cost of three individual states. With this shift in focus, the CD-ROMs are no longer sold separately, but rather sent as a no-charge add-on to an Internet subscription for a postage charge of $120 per year. Loislaw.com was acquired by Wolters Kluwer in 2000 and is now a part of Aspen Publishers.
From the consumer's perspective, there are several factors which make Loislaw.com attractive as an alternative to the major online services:
1. Loislaw.com will sell only as many passwords (permitting simultaneous access) as a firm desires.
2. Loislaw.com's flat-rate pricing is completely open. While there may be special promotions, there are no special flat-rate deals hidden by non-disclosure provisions.
3. The Loislaw.com service is available to firms and libraries of all sizes and varieties.
Single  state,	$1,080 per year	
Single state + federal circuit	$1,380 per year	
Single state + all federal	$2,100 per year -	
National Collection	$3,000 per year	
Bankruptcy Court alone	$1,,920 per year	
Bankruptcy Court add-on	$720 per year	

Loislaw.com Pricing Options
The downside of Loislaw.com is that, as a consequence of a series of pricing increases, it has ceded the ground it once occupied as the best low-cost alternative provider of computer-assisted legal research. What was once an obvious choice for those anxious to reduce online costs has become a more complex decision involving not only cost, but also firm size and likely patterns of attorney usage. With pass-words for the National Collection now priced at $3,000 each, Loislaw.com has become a less attractive option for solo practitioners and small law firms when compared to alternative national online services like VersusLaw or Fastcase which provide similar primary law coverage at substantially lower cost. The price differential is striking, but particularly so for the solo practitioner. Were it not for the fact that Loislaw.com is one of the few online providers which does not tie the sale of passwords to firm size, it would have difficulty competing with VersusLaw in a side-by-side comparison. For example, the same $3,000 it costs to buy one Loislaw.com password will buy individual VersusLaw passwords for every lawyer in a twenty-five person firm. That single Loislaw.com password must be shared, however, and only one attorney can have access at a time. Each additional password must be purchased at a cost of $3,000, although discounting may be available for multiple passwords or for those who also acquire Aspen subject content libraries. Loislaw is also receiving a stiff challenge from Casemaker which has become the default online service for many bar members whose bar associations have become part of he Casemaker consortium and provide the service as a membership benefit.
An in-depth review of Loislaw.com by T. R. Halvorson appeared in the March 1, 1999 issue of LLRX (See: www.llrx.com/features/lois2.htm). A more recent survey of CALR vendors (including Loislaw.com and VersusLaw) by Fritz Snyder and Stacey Gordon appeared in the November/December, 2000 issue of Legal Information Alert. In December, 2000, Loislaw.com was acquired by the Dutch conglomerate Wolters Kluwer and is a part of the Aspen Publishing operation.
Versus Law
Founded in 1985 by Joe Acton, VersusLaw provides lawyers with an excellent online research service at an affordable price. It was formerly known as Timeline Publishing's Lawyers Legal Research Online. In 1992, VersusLaw began working with the U.S. Supreme Court, federal circuit and state appellate courts to assemble an affordable online database of court decisions. Initially a bulletin board service (BBS), Versus Law moved to the Internet in 1995. In 1996, it changed the name of Lawyers Legal Research into V. (pronounced "vee"). Its database includes U.S. Supreme Court opinions back to 1900, most circuit court decisions back to 1930, and state court decisions as far back as 1930. The full-text searchable archive of court decisions is updated daily. Searching may be conducted via Boolean operators or natural language. The search software also supports crossfile searching. The databases also include, for an extra charge, the U.S. Code and Code of Federal Regulations, which are among the most current versions available.
VersusLaw Subscription Plans (Per Attorney) *
The Standard Plan provides access to decisions of the U.S.
Standard plan*	$9.95 per month or $119.40/ year	
Premium Plan**	$19.95 per month or $239.40/ year	
Professional Plan***	$34.95 per-month, or $419.40/ year	
United States Code	$15 per month or $180/ year	
Code of Federal regulations.	$15 per month or $180/ year	
U.S.C. and CFR	$25 per month or $300/ year	
*Supreme Court from 1900 to date, U.S. Courts of Appeals from 1930 to date, current decision of the Federal District Courts, decisions of state appellate courts (see Appendix J for specific state coverage), Tribal courts, and foreign courts.
**The Premium Plan builds on the databases provided under the Standard Plan and adds an archive of Federal District Court decisions, selected states statutes (currently 42) and regulations (currently 28), and additional search capabilities.
***The Professional Plan includes the content of the Premium Plan plus the United States, Code of Federal Regulations, and selected Special Practice Collections.
VersusLaw's flat-rate per attorney pricing structure is based on the realization that even if some attorneys are not users, the actual users are performing research for the non-users. It reflects the fact that larger firms will be using more bandwidth than small firms and should pay accordingly. All three of VersusLaw's pricing plans are arguably among the best bargains in the industry, whether for the solo practitioner or for lawyers in medium,-sized and large firms.
VersusLaw's plans to provide additional coverage of state and federal cases, statute statues and regulations. Further information regarding subscriptions and may be obtained by contacting VersusLaw at 425-250-0142, or locating VersusLaw on the Internet at: www.versuslaw.com
For a comprehensive, albeit slightly dated, review of VersusLaw, see the review by T. R. Halvorson appearing in llrx at: www.llrx.com/features/v.htm
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Pairing VersusLaw and Westlaw
While VersusLaw does not offer all the editorial bells and whistles available on the Westlaw service, it does provide the substantive primary law required by most practitioners at prices far below those of its competitors. In every match-up, VersusLaw is a lower-cost alternative, an advantage which increases as firm size grows. A considerable part of the price distinction between VersusLaw and the Westlaw PRO program is a product of Westlaw's progressively higher monthly charges as a firm grows in size. For example, assuming that a firm requires only one password, the annual costs of all primary law in a firm of 2 attorneys reveals a decided advantage for VersusLaw:
Pairing VersusLaw with Westlaw in larger firms which fall outside of the Westlaw PRO plans can result in even greater savings if VersusLaw is used as the default service. The prospective purchaser should consult with their local sales representative to determine the exact primary law coverage for the jurisdictions in which he or she practices.
	VersusLaw	Westlaw Pro	
			
All Primary Law	$477.60	$9,552.00	
In a firm of 20 attorneys, the differential
is even more pronounced: ;	
All Primary Law	$4,776.00	$45,888.00	

Other Fee-Based Legal Research Services
While the above discussion has focused on the two premium CALR services and the four leading alternative CALR providers, there are at least four other fee-based services worthy of mention. These include:
CaseClerk.com
CaseClerk.com is a reseller of CLE programs offered by VersusLaw, including eLLR, the electronic version of VersusLaw's ethics newsletter Lawyers' Liability Review. It is also a reseller of caselaw, also obtained from VersusLaw. As such, its historical caselaw coverage is identical to that of VersusLaw. The CaseClerk web site also provides users with access to federal and state statutes and regulations by means of links to official government or free commercial web sites. Data is obtained directly from official sources and the query language is standard Boolean with the ability to conduct cross-file searching. CaseClerk has a number of pricing options, including the annual plan ($49.95 per month with an annual subscription), monthly plan ($69.95 per month with a monthly subscription), daily plan ($29.95 per day with a 24hour subscription. Those with further interest are directed to the CaseClerk web site, located at: www.caseclerk.com and to the review by T.R. Halvorson appearing in Ilrx at: www.Ilrx.com/features/caseclerk.htm
CaseClerk may be contacted at (865) 397-7900, ext. 116.
Quicklaw America (see LexisNexis)
Quicklaw America, Inc. (formerly Current Legal Resources, Inc.) was founded in 1997 by a group of former West Publishing Company employees working out of the Westbury, NY office who had been responsible for the editorial work on the United States Code Annotated and a number of other federal and state publications. When that facility was closed following the acquisition of West Publishing by the Thomson Corporation, Current Legal Resources assembled 1,900 databases, including the United States Code, the Code of Federal Regulations, U.S. Statutes at Large, U.S. Supreme Court decisions, federal appeals court decisions, state appellate court decisions, and 19 topical databases containing United States statutes and regulations organized by area of practice. Launched in January, 2000, Quicklaw America also offered its subscribers access to selected state statutes and regulations, state and federal court rules, inter national materials. Most materials are obtained directly from official sources.
The history of Quicklaw America is also interwoven with that of Quicklaw, Inc, the Canadian company which acquired it in October, 1999. Quicklaw, Inc. had been providing online legal research to the Canadian and international markets since 1972. Thus, Quicklaw America is unique among the alternative online providers discussed here in that it provides Canadian and international, as well as United States, primary law. Historical caselaw coverage is similar in many respects to that of VersusLaw, CaseClerk, and Fastcase. At the time of its launching, Quicklaw America employed a proprietary search software called QUICKLINK PRO which is available for free downloading from its web site. The browser search interface, which was released on August 30, 2000, provides users with two search modes: Boolean and template. Quicklaw offers both flat-rate and transactional pricing: Quicklaw was acquired by Reed Elsevier in July, 2002. Quicklaw America was folded into the product offerings of LexisNexis. Quicklaw's Canadian offerings are now available through LexisNexis as LexisNexis Quicklaw.
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TheLaw.net
TheLaw.net, an independently held software company headquartered in San Diego, is a computer-assisted legal research service which provides access to caselaw from multiple state and federal jurisdictions and facilitates access to Web-based legal information. The caselaw content on TheLaw.net is supplied by VersusLaw. As such, it replicates VersusLaw's breadth and depth of coverage. As with VersusLaw, The Law.net provides users with the ability to conduct cross-file searching in the caselaw database. What makes The Law.net unique, however, is its stand alone Internet browser program which incorporates an extensive collection of more than 60,000 links to law-related Internet sites, largely free government sites which host statutes, regulations, forms, and other law-related content. The Internet browser is a specialized version of Opera, an alternative to Netscape and Internet Explorer which was developed by computer programmers from Norway.
For reviews of TheLaw.net, see article by Roger V. Skalbeck in Ilrx located at: www.llrx.com/features/thelawnet.htm and T.R. Halvorson located at: www.llrx.com/features/reed.htm ....
TheLaw.net is priced at $445 per year for a solo practitioner, $495 for one lawyer and one paralegal, $695 for two lawyers and two paralegals, $1,195 for five lawyers and five paralegals. Additional packages are available.
RegScan
RegScan (formerly Eastlaw and RegScanLaw), an electronic legal publisher based in Williamsport, PA, was founded by former Congressman and Attorney, Allen E. Ertel in 1987. Its original goal was to provide users with a current and fullysearchable database of federal regulations. Its offerings now include the current Code of Federal Regulations, Federal Register as well as state environmental regulations and OSHA Plans. RegScan began offering low-cost access to state and federal appellate caselaw on November 2, 2000 under the name Eastlaw, through a partnership with VersusLaw, and more recently under the name RegScanLaw. In 2003, however, it changed its name to RegScan and dropped its United States Code and state and federal caselaw databases and re-focused its attention on its regulatory offerings. For further information on RegScan, readers are directed to a review of Eastlaw by T. R. Halvorson which appeared in the January 2, 2001 issue of Ilrx at: www.IIrx.com/features/eastlaw.htm
RegScan's pricing may be obtained at http:/Iregscan.com or may be contacted by telephone at: (800) 734-7226 x1105
Public Law Library CALR Access
For many medium-sized and large firms, LEXIS and/or Westlaw are absolutely essential research tools. However, most solo practitioners and many small law firms do not use CALR with sufficient frequency to warrant having their own subscriptions. In these instances, access to a public Westlaw or Lexis terminal at your local public or bar library is probably the most cost-effective option, particularly when that access is accompanied by the expert assistance of a trained law librarian with extensive experience in performing online research.
This service is priced on a per use basis and generally reflects either the actual cost of online time or a small premium over the library's cost. Typically, there is no charge for the assistance of a trained library professional in formulating your search. If your trips to the local law library for the purpose of online research become frequent, however, you may wish to secure your own subscription with one of the online vendors discussed above.