N.D. New York cuts intellectual property fee award, including for block billing

What happened

The fee applicant in an intellectual property case sought fees, and the court awarded 20.8 hours. It cut 4.1 hours because some time entries appeared to include block billing with work performed for other matters. It reduced the hourly rate for Ms. Springer, a paralegal, because the requested rate exceeded the highest rate in the District for paralegals. The court also declined to award attorney's fees for additional work counsel anticipates. The court did not state dollar totals.

What the court said

Although the invoices submitted seem to document at least that many hours billed, some of the time entries appear to include block billing with work performed for other matters.

The court also reduced the award for: hourly rate reduced, other.

Why it matters

The ruling shows that courts will trim hours when time entries combine work for other matters, even if the invoices appear to document the hours billed. It also shows that paralegal rates are measured against district norms and that anticipated future work is not compensable on a fee petition.

How to keep this out of your fee petition

• Record one task per entry, each with its own time.
• Write the entry when the work happens, not at the end of the week.
• If a task really is one unit of work, say what it was and what it produced.

Cite this ruling

See hourly rates the N.D. New York approves and attorney fee motions in New York federal courts.

Figures and quotes are taken from the opinion and checked against its text. Spot an error? Email team@legaltime.ai with the case name and we will correct it. Summaries of public court opinions. Not legal advice.