Quicklogic Corporation v. Konda Technologies, Inc.

Background

The court had previously found that an attorneys’ fee award was appropriate under 35 U.S.C. § 285, a provision of the Patent Act, based on the litigation conduct of Konda Technologies, Inc. and Venkat Konda. The earlier order deferred deciding the reasonable amount of fees.

QuickLogic initially requested $471,382.18 for 608.9 hours worked from May 3, 2021, through July 31, 2023. It later requested additional amounts for work through January 31, 2024, and for work responding to Venkat Konda’s motion seeking relief from judgment. In its final supplemental filing, QuickLogic revised the first period’s figures to 613.34 hours and $470,186.50.

Legal standard

The court used the lodestar method, which generally calculates a reasonable fee by multiplying a reasonable hourly rate by the number of hours reasonably spent. The court could exclude hours that were excessive, duplicative, or unnecessary, and could make an across-the-board percentage reduction if appropriate.

Hourly rates

The court found the rates charged by QuickLogic’s attorneys at Baker Botts LLP reasonable. Although some rates were high compared with rates in the San Francisco Bay Area, the court found them supported by the attorneys’ experience, qualifications, and patent-litigation work.

QuickLogic provided less information about the experience and responsibilities of its senior paralegals and did not provide comparable Northern California rate evidence. Nevertheless, the court declined to reduce or deny those fees because the overall requested fees were substantially below the estimated median cost of comparable litigation, and the use of experienced paralegals with lower hourly rates presumably reduced the total cost.

Hours and fee calculation

For May 3, 2021, through July 31, 2023, the court declined to reduce the 613.34 hours requested. It rejected Venkat Konda’s claim that the hours were artificially inflated and his argument that preparation for hearings later taken under submission should not be compensated.

For August 1, 2023, through January 31, 2024, the court found 155.6 hours reasonable and declined to apply a percentage reduction. Together, the court found 768.94 hours worked through January 31, 2024 reasonable, producing an initial lodestar amount of $581,918.20.

For February 1, 2024, through May 31, 2024, QuickLogic requested $75,362.17 but did not provide the number of hours worked or supporting documentation. The court therefore denied the requested fees for that period.

The court applied an offset for settlements with attorneys Deepali Brahmbhatt and Derek Dahlgren. It then granted QuickLogic $531,918.20 in attorneys’ fees.

Disposition

The court granted QuickLogic $531,918.20 in attorneys’ fees.