Counting data is much harder than journal counting pdf articles. Data are complex objects with a variety of file formats, numerous versions, and one dataset can be part of or derived from another dataset. Earlier this year, COUNTER (represented by Paul Needham) and Make Data Count team members (Martin Fenner (DataCite), Matt Jones (DataONE), John Chodacki and Daniella Lowenberg (CDL)) met for two days to talk through the use cases, definitions, and hurdles in properly counting data usage and to put together the first iteration of the COUNTER Code of Practice for Data Usage.