Innovative Sports Management, Inc. v. Huaman
- Beth Freeman
- 5:22-cv-05796
- U.S. District Court · Northern District of California
- 7
In Innovative Sports Management v. Huaman, Judge Freeman granted in part and denied in part fees and costs, awarding $2,577.
Innovative Sports Management, Inc. received $2,100 in attorneys’ fees and $477 in costs, while its request for additional fees and costs was denied in part; Zenon Huaman was affected by the resulting award against him.
What happened
Innovative Sports Management, Inc. v. Zenon Huaman followed a default judgment in a commercial piracy case. The court had previously awarded Innovative Sports Management $1,650 in damages for conversion and violating 47 U.S.C. § 553.
The court granted in part and denied in part the company’s request for attorneys’ fees and costs. It awarded $2,100 in attorneys’ fees and $477 in costs, for a total award of $2,577. The court denied payment for administrative-assistant work, research-attorney work, certain lead-attorney hours, travel, investigative expenses, and courier charges.
Judge Beth Labson Freeman ruled that the requested attorney rates were reasonable but that the supporting time records and cost documentation did not justify the full request. The court entered the partial grant and partial denial on November 3, 2023.
The detailed version
- Innovative Sports Management, Inc. v. Huaman · No. 5:22-cv-05796
- Beth Freeman
- Nov. 3, 2023
Background
On June 23, 2023, the court granted Innovative Sports Management, Inc.’s motion for default judgment in a commercial piracy case. It awarded the company $1,650 in damages for conversion and under 47 U.S.C. § 553. The company then sought attorneys’ fees and costs under § 553(c)(2)(C).
Attorneys’ Fees
The court used the lodestar method, which calculates fees by multiplying reasonable hours by a reasonable hourly rate. It found the requested rates reasonable: $600 per hour for lead attorney Thomas P. Riley and $325 per hour for a research attorney.
The court denied the $1,414.80 requested for 11.79 hours of administrative-assistant work because such work is ordinarily treated as firm overhead in the Northern District of California. It also denied the $3,331.25 requested for 10.25 hours of research-attorney work because the motion did not identify that attorney by name or provide enough information to show that the requested rate was reasonable in the local market.
The company requested $3,540 for 5.9 hours of lead-attorney work. The court reduced that request by $1,440, corresponding to 2.4 hours it found excessive or unnecessary because the tasks were repetitive and could be completed more quickly by an experienced attorney. In total, the court reduced the requested fee award by $6,186.05 and awarded $2,100 in attorneys’ fees.
Costs
The company requested $1,594.50 in costs, including an airline flight, Uber rides, the complaint filing fee, service of process, courier charges, and investigative expenses. The court awarded $402 for the filing fee and $75 for service of process, for a total of $477 in costs.
The court denied $1,117.50 for travel, investigative expenses, and courier charges. It found that the company provided no receipts or invoices for the flight or Uber rides and saw no reason to award the investigative and courier expenses in this type of case.
Order
The court granted in part and denied in part Innovative Sports Management’s motion for attorneys’ fees and costs. It awarded the company $2,577 in reasonable attorneys’ fees and costs. Judge Beth Labson Freeman also vacated the hearing previously scheduled for December 14, 2023.
Read the full 7-page opinion on CourtListener, the free public archive maintained by the Free Law Project.