Onemata Corporation v. Rahman, 0:20-cv-62002

Background

Onemata (successor to Enscicon) sued Defendants after acquiring LocalBlox, alleging false representations, breach of the Stock Purchase Agreement, and related claims; Defendants counterclaimed and impleaded third parties.
The Stock Purchase Agreement expressly incorporated multiple promissory notes (the Notes), which contained a unilateral fee clause awarding Payee attorney’s fees for costs of collection.
A jury returned verdict for Onemata on all counts; district court entered final judgment against Defendants and the Onemata Parties moved for attorney’s fees, taxable costs, and nontaxable costs.
Central legal questions: whether Fla. Stat. § 57.105(7) makes the unilateral fee clause reciprocal; whether reciprocal fees extend beyond collection claims to all claims in the case; and whether § 57.105(7) permits recovery of nontaxable costs.
The magistrate judge recommended awarding reciprocal attorney’s fees (but reduced by 10% for block billing), denying recovery of nontaxable costs under § 57.105(7), and awarding a reduced amount of taxable costs under 28 U.S.C. § 1920.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Entitlement to fees under contract / § 57.105(7)	Stock Purchase Agreement incorporates Notes; § 57.105(7) makes unilateral fee clause reciprocal to prevailing party	Fee clause limited to collection claims; Onemata is not (originally) a party to the Notes	Granted: Notes incorporated; § 57.105(7) applies; Onemata (as Enscicon successor) entitled to reciprocal fees
Scope of fee recovery (beyond collection)	Claims arise from same transaction/contracts and are inextricably intertwined; therefore all reasonable fees are recoverable	Fee clause should be read as collection-only and not cover unrelated claims	Granted: claims share common core of facts; apportionment impractical; fees for all claims awarded
Reasonableness / amount of fees	Requests supported by billing records and market rates	Opposes full award; alleges block billing and asks 25% across-the-board reduction	Partially granted: requested hourly rates accepted; 10% across-the-board reduction for billing inefficiencies; lodestar awarded $904,149
Recovery of nontaxable costs under § 57.105(7)	Nonspecific: contractual/“expansive provision” should allow nontaxable costs	Argues statute limits reciprocal relief to attorney’s fees	Denied: § 57.105(7) authorizes reciprocal attorney’s fees only, not nontaxable costs
Taxable costs under § 1920 (specific categories)	Seeks $40,670.79 for filing, service, transcripts, witness fees, copies, docket fees	Challenges excess private process fees, certain transcript charges, copying, and multiple service attempts	Partially granted: total taxable costs reduced to $34,591.09 after (inter alia) (i) service costs limited to U.S. Marshal rates ($845), (ii) transcript charges reduced to exclude litigation-convenience items ($27,732.20), (iii) witness fees and docket fees awarded, copying disallowed

Key Cases Cited

Hensley v. Eckerhart, 461 U.S. 424 (1983) (lodestar method and billing judgment principles for fee awards)
Norman v. Housing Auth. of Montgomery, 836 F.2d 1292 (11th Cir. 1988) (fee applicant burden to document hours and rates)
Ham v. Portfolio Recovery Associates, LLC, 308 So. 3d 942 (Fla. 2020) (Florida Supreme Court construing § 57.105(7) reciprocal application)
Page v. Deutsche Bank Tr. Co. Americas, 308 So. 3d 953 (Fla. 2020) (interpretation of § 57.105(7) prongs)
U.S. EEOC v. W&O, Inc., 213 F.3d 600 (11th Cir. 2000) (when deposition costs are taxable under § 1920)
Loranger v. Stierheim, 10 F.3d 776 (11th Cir. 1994) (use of lodestar approach)
Bivins v. Wrap It Up, Inc., 548 F.3d 1348 (11th Cir. 2008) (hour-by-hour analysis or across-the-board reductions for excessive hours)
Crawford Fitting Co. v. J. T. Gibbons, Inc., 482 U.S. 437 (1987) (scope of taxable costs under § 1920)
SE Prop. Holdings, LLC v. Welch, 65 F.4th 1335 (11th Cir. 2023) (applying Florida Supreme Court precedent on § 57.105(7) in federal diversity context)