Midas International Corporation v. Poulah Investors, LLC, 8:15-cv-02240

Midas International (franchisor) and J&D Automotive (franchisee) had a Franchise Agreement that required payment of royalties, restricted use of Midas trademarks after termination, and contained a provision entitling Midas to attorneys’ fees and related expenses to enforce the agreement.
J&D assigned the franchise to Poulah Investors, LLC; several individuals were named as related parties and guarantors.
The Franchise Agreement expired November 7, 2014; Poulah continued to operate using the Midas mark and logo and became delinquent on financial obligations.
Midas sued for trademark infringement, breach of contract (against Poulah), and breach of guaranty (against individual defendants). Some individual defendants were previously dismissed; Poulah defaulted.
The court previously entered default judgment against Poulah and summary judgment for Midas on breach/guaranty claims; trademark claim remained but other claims were effectively adjudicated in Midas’s favor.
Midas moved for attorneys’ fees and costs under the Franchise Agreement; the court awarded $30,020.00 in attorneys’ fees plus $1,011.30 in costs (previously taxed), with post-judgment statutory interest.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Entitlement to attorneys’ fees under the Franchise Agreement	Midas argued the fee-shifting clause covers fees incurred to enforce Franchise Agreement obligations and to obtain the judgment showing Poulah’s default	Defendants did not oppose the motion	Court held Midas is entitled to fees under §10.4 because Midas prevailed and established Franchisee default
Proper fee calculation method	Midas relied on lodestar (reasonable hours × reasonable rates) and provided declarations, time records, and rate justifications	No opposition or competing rate/hour showing from defendants	Court applied lodestar, reviewed submissions, and found the requested rates and hours reasonable
Hourly rates requested	Midas sought rates for RWO attorneys consistent with Local Rule Appendix B and $385 for LEB counsel	No opposition	Court found requested rates fall within or are corroborated by Appendix B and publicly available information, and were reasonable
Costs requested	Midas sought $1,011.30 in costs (clerk-taxed costs include filing and process service fees)	No opposition	Court approved previously-taxed costs of $1,011.30

Hensley v. Eckerhart, 461 U.S. 424 (lodestar standard for fee awards)
Rich Creek Coal Sales, Inc. v. Caperton, 31 F.3d 169 (hours reduction and billing judgment principles)
NIFA Research, Inc. v. Imake Leasing Co., 405 Md. 435 (contractual fee-shifting under Maryland law)