S.D. Florida cuts intellectual property fee award 10%, including for vague entries

What happened

The fee applicant in LongeviQuest, LLC v. Kroczek requested $24,797.50 for 50.8 hours. Judge Aileen M. Cannon awarded $22,317.75, a reduction of $2,479.75 or 10%. The court applied a 10% cut to the total fee for four reasons: some entries showed multiple timekeepers billing for the same task; some showed partners billing for routine procedural matters that could have been handled by an associate or paralegal at lower rates; some entries had unclear descriptions, such as those labeled CANNON RE SAME and EXPRESS; and some included administrative tasks such as filing and preparing notices.

What the court said

Some billing entries have unclear descriptions. For example, the entries labeled “CANNON RE SAME” and “EXPRESS” lack explanation as to the work performed.

Some billing entries include administrative tasks such as filing and preparing notices. (DE 24-1 at 5). The Court finds that purely administrative tasks should not be compensable.

The court also reduced the award for: duplicative staffing, excessive hours.

Why it matters

The ruling shows that a single 10% cut can rest on several distinct problems in the time records, including vague descriptions and administrative tasks billed as legal work. It also shows courts will reduce fees for duplicative staffing and for partner time spent on routine matters.

How to keep this out of your fee petition

• Name the task, the document or person involved, and the purpose.
• Avoid stock phrases that could describe any day in any matter.
• Keep privileged detail general, but specific enough to show the work.

Cite this ruling

See hourly rates the S.D. Florida approves and attorney fee motions in Florida 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.