Federal Trade Commission v. Ecom Genie Consulting LLC, 1:24-cv-23976

The court appointed Mark Bernet as receiver over entities suspected of violating the Federal Trade Commission Act, granting him authority over assets and operations.
The Receivership Order entitled the Receiver and his personnel to reasonable compensation for services and reimbursement of actual expenses.
The Receiver submitted detailed applications for payment of fees and expenses for himself, his deputy, and the law firm Akerman LLP for services rendered up to June 30, 2025.
The applications included billing for a broad range of tasks including asset control, litigation, financial investigations, and management of electronic information.
No parties objected to the requested amounts, but the court reviewed the reasonableness of the hourly rates and total amounts claimed, especially by paralegals.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Entitlement to receiver’s fees and expenses	Receiver is entitled under the order	No objection	Receiver’s requested fees and expenses are granted.
Reasonableness of receiver hourly rates	$480/hour is reasonable and below market	No objection	$480/hour approved as reasonable.
Reasonableness of paralegal hourly rates (Akerman LLP)	$320/hour is reasonable for experience	No objection	Reduced to $150/hour; amount recalculated.
Reimbursement of costs to receiver and Akerman	All costs are documented and necessary	No objection	All documented costs approved for reimbursement.

Hensley v. Eckerhart, 461 U.S. 424 (lodestar method for calculating reasonable attorney's fees)
Loranger v. Stierheim, 10 F.3d 776 (use of lodestar method for fee awards)
Norman v. Housing Auth. of Montgomery, 836 F.2d 1292 (court review of hours and rates for reasonableness)
S.E.C. v. Elliott, 953 F.3d 1560 (receiver’s right to compensation and expense reimbursement)