D. Hawaii cuts intellectual property fee award 21.6% over block billing

What happened

Capstone Studios sought $18,787.50 in attorney fees for 41.5 hours in an intellectual property case. The court found that several time entries were inappropriately block billed and recommended striking 10.25 hours from the award. It awarded $14,725.13, a reduction of $4,062.37, or 21.6%, leaving 31.25 hours. The figures do not include costs.

What the court said

The Court, however, FINDS that the following entries are inappropriately block billed... The Court RECOMMENDS that these entries, totaling 10.25 hours, be stricken from the award.

Why it matters

The ruling shows that courts will strike time entries that combine multiple tasks without separating the time spent on each, reducing the fee award accordingly. It reinforces that fee applicants must keep time records detailed enough for the court to assess the reasonableness of each task.

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 D. Hawaii approves and attorney fee motions in Hawaii 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.