Reiffer v. NYC Luxury Limousine Ltd

Background

On June 15, 2023, the court granted Paul Reiffer’s motion for summary judgment. In that earlier decision, the court also determined that Reiffer was entitled to attorney’s fees and costs under Sections 505 and 1203 of the Copyright Act. The court directed Reiffer to file a fee motion, which he filed on June 23, 2023. NYC Luxury Limousine Ltd. did not file an opposition.

Attorney’s Fees

The court used the lodestar method, which generally calculates a fee by multiplying a reasonable hourly rate by the reasonable number of hours worked. It found reasonable the rates charged by partners Joseph A. Dunne and Evan Andersen at $450 per hour, associate Eliezer Lekht at $325 per hour, and the paralegals at rates ranging from $175 to $200 per hour. The court also found that the approximately 70 hours billed by counsel and the paralegals were reasonable and that the case was efficiently staffed and litigated.

The court did not award fees for 0.6 hours billed by Laura Yepes and Tyler Unfer, who were identified as client-services liaisons. The court found that the work described in their billing entries was purely clerical and therefore not compensable as attorney or paralegal work.

Costs

The court approved Reiffer’s request for $491.20 in costs: a $402 filing fee and $89.20 for service of process. The court found those expenses adequately supported by the docket, an invoice, and counsel’s affidavit.

Disposition

The court awarded Reiffer $28,620 in attorney’s fees and $491.20 in costs. Together with the $30,500 in statutory damages previously awarded, the judgment totaled $59,611.20 against NYC Luxury Limousine Ltd. The Clerk of Court was directed to enter judgment, terminate the pending fee motion, and close the case.