Smart Team Global LLC v. Humbletech LLC

Background

Smart Team Global LLC sued Humbletech LLC and Li over alleged breach-of-contract claims and alleged violations of the Virginia Uniform Trade Secrets Act and the federal Defend Trade Secrets Act. Humbletech initially appeared, and the parties engaged in initial discovery and motion practice. After Humbletech’s lawyer withdrew, Humbletech did not make further efforts to defend the case. Li never appeared.

The court had previously adopted the magistrate judge’s report and recommendation and granted in part Smart Team Global’s motion for default judgment. The court also concluded that Smart Team Global had shown an entitlement to reasonable attorneys’ fees and costs under the federal Defend Trade Secrets Act and Virginia law. It directed Smart Team Global to file its fee application within 30 days after judgment. Judgment was entered on March 22, 2022, and Smart Team Global filed the application on April 22, 2022. The defendants did not oppose it.

Fee standard and ruling

The court used the lodestar method, which calculates a presumptively reasonable fee by multiplying a reasonable hourly rate by a reasonable number of hours. It explained that courts may reduce fees for excessive, redundant, or unnecessary work and have substantial discretion in setting the award.

For partner rates, the court reduced S.Y. Lee’s 2021 rate from $825 to $720 per hour and G.P. Barbatsuly’s 2022 rate from $785 to $700 per hour. The court found the other attorney rates reasonable. It reduced the rates for three paralegals and one librarian to $100 per hour because Smart Team Global provided no evidence justifying the higher requested rates. These rate reductions lowered the award by $1,013.20 and $1,480.95, respectively.

The court found the billed hours reasonable overall. It excluded one redundant 1.20-hour entry for Lee, reducing the award by $864, but declined to reduce the award for alleged overstaffing. The court awarded $139,793.62 in attorneys’ fees.

The court also approved $2,301.11 in documented costs, consisting of computerized legal research, court, process-server, research-service, and courier costs. The opinion states that the court awarded a total of $142,094.73 in attorneys’ fees and costs and that the fee motion resolved Docket No. 71.

Disposition and ambiguity

The opinion’s earlier sections describe Smart Team Global as the applicant and the party entitled to the award. However, the final conclusion states: “Defendants are awarded $139,793.62 in attorneys’ fees and $2,301.11 in costs.” The text does not explain this apparent party-label error, so the recipient of the award should be treated as unclear from the conclusion, despite the surrounding discussion indicating that Smart Team Global was the intended recipient.