Jiangmen Benlida Printed Circuit Co., Ltd. v. Circuitronix, LLC
0:21-cv-60125
S.D. Fla.Apr 26, 2024Background
- Jiangmen Benlida Printed Circuit Co., Ltd. (Benlida) sued Circuitronix, LLC (CTX-US) for breach of contract and account stated; CTX-US counterclaimed for breach of contract.
- The court granted summary judgment for CTX-US on Benlida’s claims, and a jury awarded $7,585,847 to CTX-US on its counterclaim, making CTX-US the prevailing party.
- CTX-US filed an unopposed motion for attorneys’ fees and costs based on a contractual fee-shifting provision.
- The court independently reviewed CTX-US’s requested fees and costs, despite Benlida’s lack of opposition, to ensure reasonableness and compliance with local rules.
- Some of CTX-US’s claimed fees and costs were reduced for block billing, insufficient documentation, and duplicative or vague entries.
- The court recommended awarding $1,786,565.25 in attorney’s fees and $638,102.14 in costs, with possible future supplementation if better documentation is provided.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Entitlement to Fees & Costs | Not explicitly opposed; did not respond | As prevailing party, entitled per contract | Entitled: Fee-shifting provision in contract applies to CTX-US |
| Reasonableness of Fees | No challenge | Fees based on reasonable hours/rates; detailed support | Most fees reasonable, but reductions for block billing and double billing |
| Reasonableness of Costs | Objected only to computerized legal research costs | All sought costs are recoverable under contract | Most costs allowed; some denied for inadequate documentation or vague description |
| Scope of Fee-Shifting | (N/A; did not respond) | Contract covers all court costs and reasonable fees | Court applies contract as written, but only reasonable/documented costs recoverable |
Key Cases Cited
- Hensley v. Eckerhart, 461 U.S. 424 (1983) (discussing standards for entitlement and reasonableness of attorneys' fees)
- Norman v. Housing Auth. of Montgomery, 836 F.2d 1292 (11th Cir. 1988) (defining reasonable hourly rate and documenting fee requests)
- Prime Ins. Syndicate, Inc. v. Soil Tech Distributors, Inc., 270 F. App’x 962 (11th Cir. 2008) (applying state law for fees in diversity cases)
- Dade Cnty v. Pena, 664 So. 2d 959 (Fla. 1995) (fee-shifting limited to statute or contract in Florida)
- Loranger v. Stierheim, 10 F.3d 776 (11th Cir. 1994) (burden is on movant to submit documentation for costs/expenses)