Zest IP Holdings, LLC, et al v. Implant Direct MFG, LLC, et al, 3-10-cv-00541 (CASD December 3, 2014, Order) (Curiel, J.)
Friday, December 5, 2014
Quarter-Hour Billing Increment Justifies 20% Reduction in Fee Award
The court partially granted plaintiffs' motion for sanctions but reduced the award by 20% to account for overbilling attributable to quarter-hour billing increments. "Defendants claim that Plaintiffs’ practice of billing in quarter-hour increments artificially inflates their hours, and that courts in the Ninth Circuit have criticized that practice for its tendency to cause excessive billing. . . . Plaintiffs’ quarter-hour billing practice, in general, likely resulted in some requests for excessive hours. For instance, Plaintiffs seek reimbursement for discussions and meetings with co-counsel, drafting an email to co-counsel, participating in conference calls with co-counsel, and attending a client conference. These activities . . . likely took only a fraction of the time billed."