What is Bates numbering?

Bates numbering is the document-identification convention used in US litigation. Every page in a discovery production receives a unique alphanumeric identifier — typically a prefix that identifies the producing party (or case) followed by a zero-padded sequence number. The numbering is continuous across the entire production: document 1 might be SMITH000001 through SMITH000045, document 2 starts at SMITH000046, and so on. The system was invented in 1891 by the Bates Manufacturing Company, which made a mechanical hand-stamp for sequentially numbering pages; the digital equivalent today is software overlay, but the function — a unique citable identifier per page — is identical.

Why does every page need its own Bates number?

Because a litigation often produces hundreds of thousands of pages, and any one of them might be quoted in a deposition, a motion, or a trial exhibit. Without a unique citable identifier, both sides would be reduced to "the document attached to the email of June 4 from Jane Smith to Bob Jones discussing the Q3 pricing model" — unworkable at scale. With Bates numbers, the same reference is "SMITH012345", which both sides can locate immediately. The Federal Rules of Civil Procedure (Rule 34) and most state rules require produced documents to be organised "as they are kept in the usual course of business" or labelled to correspond to the categories in the request — Bates numbering is the standard mechanism for the latter.

How do I pick a prefix?

The prefix should identify the producing party (or sometimes the case) at a glance and not collide with other prefixes used in the same case. Common conventions: producing party's name or abbreviation (SMITH, ACME); a code referencing the case (XYZ_v_ABC); or a neutral identifier (PROD for "producing party", DEF for "defendant"). Avoid generic strings like "DOC" or "FILE" that would collide if combined with another production. Length is typically 3–8 uppercase letters. Once chosen, the prefix must remain consistent across every production in the case — re-prefixing mid-case requires re-numbering everything and is a giant headache.

What is the difference between Bates numbers and Document Control Numbers?

Bates numbers are per-page identifiers used on the face of the produced document. Document Control Numbers (DCNs) are per-document identifiers maintained in the producing party's internal e-discovery database — Relativity, Logikcull, Everlaw, etc. The two are related but distinct: one document might have a DCN of "DOC-2024-08-15-00042" and a Bates range of "SMITH000345 through SMITH000389". The receiving party sees only the Bates numbers; the producing party uses DCNs internally for review, redaction, and privilege logging. Most e-discovery platforms maintain the link between the two automatically.

Do I need Adobe Acrobat Pro to apply Bates numbering?

No. Adobe Acrobat Pro has a Bates numbering feature, but several free tools handle it just as well. ScoutMyTool's Bates Numbering tool runs in your browser and applies a continuous Bates sequence across one or many PDFs without uploading anything. PDF-XChange Editor (Windows) and pdftk (CLI) both handle Bates stamps. For very large productions (hundreds of thousands of pages), dedicated e-discovery platforms (Relativity, Logikcull, Everlaw) embed Bates numbering as part of their production workflow — they are worth the cost for matters above a certain scale.

How are confidentiality designations applied?

When a protective order designates a subset of documents as "Confidential" or "Attorneys' Eyes Only" (AEO), each designated page must carry the corresponding stamp in addition to the Bates number. Typical placement: the designation stamp appears above the Bates number in the footer, or alongside it. The exact wording is dictated by the protective order — "CONFIDENTIAL — SUBJECT TO PROTECTIVE ORDER" is common. Stamp only the pages of the documents the designation applies to; mass-designating everything wastes attorney review time and may waive the privilege under "the same as" doctrines in some jurisdictions.

What happens if I have to re-produce a document — does it get a new Bates number?

It depends on the protective order or production protocol. The most common rule is that Bates numbers do not change once assigned — if a document was originally produced as SMITH000045-67, the same document re-produced (after a redaction change, an OCR re-run, etc.) keeps the same Bates range and is delivered as a "replacement" rather than a new production. Some protocols use a "version suffix" (SMITH000045.1, SMITH000045.2) for revisions. Both sides should agree on the convention up front; it is one of the standard topics in the FRCP Rule 26(f) meet-and-confer at the start of the case.

Bates numbering for legal PDFs — add to discovery documents (2026)

11 min read

Bates numbering for legal PDFs — add to discovery documents (2026)

By ScoutMyTool Editorial Team · Last updated: 2026-05-20

A quick note

This article is general information about the Bates numbering convention, not legal advice. Production protocols vary by jurisdiction, case, and protective order. Confirm specifics with counsel and the relevant Rule 26(f) order before adopting any convention from this article in an actual matter.

The first time I had to produce documents in a case, I assumed Bates numbering was a quaint historical convention — a thing lawyers did because lawyers had always done it. The first time I tried to find one specific page of a 47,000-page production without Bates numbers, I learned why the convention exists. Without a unique citation per page, the production becomes a haystack with no needles. With Bates, "SMITH012345" lands on exactly one page, instantly, on both sides of the matter. This article is the practical guide to applying Bates numbering to a discovery production in 2026 — the conventions that matter, the confidentiality stamps that travel with them, and the free tools that handle the mechanical work.

Where Bates numbering came from

The convention is named after the Bates Manufacturing Company, which in 1891 patented a hand-held mechanical stamp machine that sequentially numbered pages — press the stamp on a page and the internal mechanism auto-incremented the number for the next press. Law firms adopted the machine for marking documents during discovery, and the term "Bates number" stuck even after the physical stamp gave way to software overlay in the 1990s. The function remained the same: a unique, citable identifier on every page of every document in a production.

Today every commercial e-discovery platform — Relativity, Logikcull, Everlaw, Reveal, Disco — has Bates numbering built into its production workflow, and most free PDF tools support it as a feature alongside page-numbering. The Federal Rules of Civil Procedure do not name "Bates numbering" specifically, but Rule 34(b)(2)(E) requires produced documents to be organised "as they are kept in the usual course of business" or "labelled to correspond to the categories in the request" — Bates is the de-facto mechanism for the latter.¹

Anatomy of a Bates stamp — the six conventions

Field	Typical value	Example	Notes
Prefix	3–8 uppercase letters identifying the producing party or case	SMITH, ACME, PROD, DEF	Use a prefix the receiving party can decode at a glance. Avoid generic prefixes like "DOC" that would collide if combined with another production.
Number padding	6 zero-padded digits	000001 through 999999	Six digits handles up to one million pages. Use 7 if you expect more; 8 if you are running enterprise litigation. The padding makes the strings sort correctly as text.
Separator	No separator, or hyphen / underscore	SMITH000001 or SMITH-000001 or SMITH_000001	Pick one convention for the entire production and stick with it. Mixing separators within a single production confuses downstream tools.
Position on page	Bottom right; sometimes bottom center	SMITH000001 at footer right	Bottom right is the most common; gives the Bates room without colliding with the page content above. Always outside the cropped page area so it survives if the page is reprinted.
Font	9–10 pt Helvetica / Arial in solid black	SMITH000001 (Helvetica 10pt)	Legible at print scale; not so large that it dominates the page. Avoid coloured or stylised fonts — the Bates stamp is functional, not decorative.
Confidentiality endorsement	Stamped above or below the Bates number	"CONFIDENTIAL" or "HIGHLY CONFIDENTIAL — ATTORNEYS’ EYES ONLY"	When a protective order designates documents as confidential, the endorsement must accompany every page of the designated documents. Apply both stamps in the same pass to keep their relative position consistent.

Confidentiality endorsements — the second stamp

Most modern litigation operates under a protective order that designates some documents as confidential (often two tiers: "Confidential" and "Highly Confidential — Attorneys' Eyes Only"). The endorsement is a second stamp applied alongside the Bates number on every page of every designated document — typically stacked above or below the Bates, in the same general footer area. The wording is dictated by the protective order; common variants include:

"CONFIDENTIAL" — basic single-tier designation.
"CONFIDENTIAL — SUBJECT TO PROTECTIVE ORDER" — common in federal practice.
"HIGHLY CONFIDENTIAL — ATTORNEYS' EYES ONLY" — the second tier, restricting access to outside counsel.
"CONFIDENTIAL — OUTSIDE COUNSEL ONLY" — variant of AEO.
"PRIVILEGED & CONFIDENTIAL" — for documents being produced under a partial-privilege protocol.

Apply the designation only to the pages of the documents the designation actually covers. Mass-designating an entire production as "Confidential" — known as "over-designation" — wastes the receiving party's review time, may waive the designation in some jurisdictions under the "Confidentiality designations must be made in good faith" doctrine, and exposes the designating party to sanctions under Rule 26(g). The Sedona Conference Principles 2nd Edition explicitly warns against over-designation as an e-discovery anti-pattern.²

The six-step Bates workflow

Step	What to do	Notes
1. Assemble the production set	Gather all documents to be produced into a single ordered set. Order by document family (parent + attachments together) or by date, whichever the production protocol specifies.	The order at this step determines the Bates sequence. Re-ordering after stamping requires re-stamping; Bates numbers should not change between productions.
2. Merge into one PDF (optional but recommended)	Merge the production into a single PDF so Bates numbering can be applied in one continuous pass.	Use Merge PDF; preserve document boundaries by adding a single blank page between documents if you need to split back later.
3. Apply Bates numbering	Run the merged PDF through a Bates numbering tool. Set prefix, starting number, padding, position, and font.	Verify the first 5 pages and the last 5 pages look correct before processing the entire set — catches misconfigurations early.
4. Add confidentiality endorsements	For documents subject to a protective order, overlay the relevant confidentiality designation ("CONFIDENTIAL", "AEO", etc.).	Only on the documents the designation actually applies to — wrongly designating documents wastes attorney review time and may waive protections.
5. Split back into individual documents (optional)	If the receiving party expects individual files (one PDF per document), use Split by Bookmarks or Split by Page Range to break the merged set back into per-document files named with their Bates range.	File names should embed the Bates range — e.g., "SMITH000045-SMITH000089_Email_re_PriceList.pdf" — so the receiving party can find documents by Bates.
6. Verify with a sample audit	Open a random sample of 20–30 pages and confirm the Bates appears as expected, the page count matches the production log, and confidentiality stamps land on the designated pages.	Catching a misconfiguration here is much cheaper than catching it after the production has gone out.

Applying Bates numbering in ScoutMyTool — five steps

Open the tool. Go to scoutmytool.com/pdf/pdf-bates-numbering. The tool runs entirely in your browser; the production set never leaves your machine.
Upload the merged production PDF. Use Merge PDF first to combine the production into a single ordered file, then feed it to the Bates tool.
Set the Bates parameters. Prefix (e.g., "SMITH"), starting number (typically 000001), padding (6 digits is standard), position (bottom right), font (Helvetica 10pt black). Preview shows what the first page will look like.
Optionally add a confidentiality endorsement. A second overlay applied alongside the Bates number; specify the wording and the page ranges that the designation covers.
Generate and split. The tool writes the Bates-stamped PDF. Use Split by Bookmarks (if the merge preserved document boundaries as bookmarks) or Split PDF by page range to break the stamped merge back into per-document files named with their Bates ranges.

Document families — keep parents and attachments together

"Document families" are a key e-discovery concept: an email and its attachments form a family, where the email is the parent and the attachments are children. The Bates convention is to give the parent and all its children a contiguous Bates range — if an email is SMITH000045 (one page) and has three attachments of 4, 7, and 2 pages respectively, the family occupies SMITH000045 through SMITH000058. Breaking up a family across non-contiguous Bates ranges is a violation of most production protocols and makes downstream review and citation much harder.

When merging documents prior to Bates stamping, sort family members together: parent first, attachments in their original order. Most e-discovery platforms handle this automatically; manual productions need to preserve family relationships explicitly.

PDF Bates Numbering — the primary tool referenced.
Merge PDF — combine the production set before Bates stamping.
Split by Bookmarks — break the stamped production back into per-document files.
Split PDF — split by explicit page ranges.
PDF Redact — apply redactions before Bates stamping (redactions live within the page content; Bates numbers are overlays added on top).
Protect PDF — password-protect the final production set before delivery.
Add page numbers, headers and footers — sister article that covers regular page numbering and includes a Bates-numbering primer.
PDF/A conversion — many production protocols deliver as PDF/A; apply Bates first, then convert to PDF/A.

Frequently asked questions

What is Bates numbering?: Bates numbering is the document-identification convention used in US litigation. Every page in a discovery production receives a unique alphanumeric identifier — typically a prefix that identifies the producing party (or case) followed by a zero-padded sequence number. The numbering is continuous across the entire production: document 1 might be SMITH000001 through SMITH000045, document 2 starts at SMITH000046, and so on. The system was invented in 1891 by the Bates Manufacturing Company, which made a mechanical hand-stamp for sequentially numbering pages; the digital equivalent today is software overlay, but the function — a unique citable identifier per page — is identical.
Why does every page need its own Bates number?: Because a litigation often produces hundreds of thousands of pages, and any one of them might be quoted in a deposition, a motion, or a trial exhibit. Without a unique citable identifier, both sides would be reduced to "the document attached to the email of June 4 from Jane Smith to Bob Jones discussing the Q3 pricing model" — unworkable at scale. With Bates numbers, the same reference is "SMITH012345", which both sides can locate immediately. The Federal Rules of Civil Procedure (Rule 34) and most state rules require produced documents to be organised "as they are kept in the usual course of business" or labelled to correspond to the categories in the request — Bates numbering is the standard mechanism for the latter.
How do I pick a prefix?: The prefix should identify the producing party (or sometimes the case) at a glance and not collide with other prefixes used in the same case. Common conventions: producing party's name or abbreviation (SMITH, ACME); a code referencing the case (XYZ_v_ABC); or a neutral identifier (PROD for "producing party", DEF for "defendant"). Avoid generic strings like "DOC" or "FILE" that would collide if combined with another production. Length is typically 3–8 uppercase letters. Once chosen, the prefix must remain consistent across every production in the case — re-prefixing mid-case requires re-numbering everything and is a giant headache.
What is the difference between Bates numbers and Document Control Numbers?: Bates numbers are per-page identifiers used on the face of the produced document. Document Control Numbers (DCNs) are per-document identifiers maintained in the producing party's internal e-discovery database — Relativity, Logikcull, Everlaw, etc. The two are related but distinct: one document might have a DCN of "DOC-2024-08-15-00042" and a Bates range of "SMITH000345 through SMITH000389". The receiving party sees only the Bates numbers; the producing party uses DCNs internally for review, redaction, and privilege logging. Most e-discovery platforms maintain the link between the two automatically.
Do I need Adobe Acrobat Pro to apply Bates numbering?: No. Adobe Acrobat Pro has a Bates numbering feature, but several free tools handle it just as well. ScoutMyTool's Bates Numbering tool runs in your browser and applies a continuous Bates sequence across one or many PDFs without uploading anything. PDF-XChange Editor (Windows) and pdftk (CLI) both handle Bates stamps. For very large productions (hundreds of thousands of pages), dedicated e-discovery platforms (Relativity, Logikcull, Everlaw) embed Bates numbering as part of their production workflow — they are worth the cost for matters above a certain scale.
How are confidentiality designations applied?: When a protective order designates a subset of documents as "Confidential" or "Attorneys' Eyes Only" (AEO), each designated page must carry the corresponding stamp in addition to the Bates number. Typical placement: the designation stamp appears above the Bates number in the footer, or alongside it. The exact wording is dictated by the protective order — "CONFIDENTIAL — SUBJECT TO PROTECTIVE ORDER" is common. Stamp only the pages of the documents the designation applies to; mass-designating everything wastes attorney review time and may waive the privilege under "the same as" doctrines in some jurisdictions.
What happens if I have to re-produce a document — does it get a new Bates number?: It depends on the protective order or production protocol. The most common rule is that Bates numbers do not change once assigned — if a document was originally produced as SMITH000045-67, the same document re-produced (after a redaction change, an OCR re-run, etc.) keeps the same Bates range and is delivered as a "replacement" rather than a new production. Some protocols use a "version suffix" (SMITH000045.1, SMITH000045.2) for revisions. Both sides should agree on the convention up front; it is one of the standard topics in the FRCP Rule 26(f) meet-and-confer at the start of the case.

Apply Bates numbering in your browser, free

Browser-based; production set never leaves your machine. Continuous numbering, confidentiality endorsements, and per-document splits all supported.

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