Edlong Corp. v. Nadathur, 2013 Ohio 1283

Nadathur signed a confidentiality agreement with Edlong limiting disclosure; after leaving Edlong for Givaudan, Edlong sued Nadathur and Givaudan for trade secrets and breach, seeking injunctive relief.
Givaudan and Nadathur counterclaimed for tortious interference.
Trial court denied injunctive relief and Edlong lost on breach-of-contract and trade-secret claims; appellate court affirmed.
Post-trial, Nadathur sought attorney fees under the confidentiality agreement’s prevailing-party provision; the court awarded fees only for the breach-of-contract claim.
Magistrate determined fees were not divisible and Nadathur was to recover only half his claimed fees; trial court adopted this, remanding for amounts.
On appeal, Nadathur argues the fees are indivisible and the court abused its discretion by halving them; the court agrees and reverses, remanding for full fee award.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether fees were properly reduced to half.	Nadathur; fees are indivisible due to intertwined claims.	Edlong; fees should be allocated by claim.	Abuse of discretion; fees indivisible require full recovery.

Bittner v. Tri-County Toyota, Inc., 58 Ohio St.3d 143 (1991) (fees recoverable where claims separable; determine amount reasonably necessary)
Lambda Res., Inc. v. Jacobs, 2013-Ohio-348 (Ohio 1st Dist.) (explains non-deductive allocation when multiple claims share core facts)
Parker v. I & F Insulation Co., 1st Dist. No. C-960602 (1998) (discusses allocation; not to rely on simple success ratio)
Hensley v. Eckerhart, 461 U.S. 424 (1983) (multifactor assessment of hours for fee-shifting; not always proportional to success)
New Concept Hous., Inc. v. United Dept. Stores Co., 2009-Ohio-2259 (Ohio 1st Dist.) (courts consider relatedness of claims when awarding fees)