CEATS, INC. v. TICKETNETWORK, INC. and TICKET SOFTWARE, LLC

District Court, E.D. Texas·Decided August 31, 2026·No. 2:15-cv-01470·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION

CEATS, INC., § § Plaintiff, § § v. § § CIVIL ACTION NO. 2:15-CV-01470-JRG TICKETNETWORK, INC., and § TICKET SOFTWARE, LLC, § § Defendants. §

MEMORANDUM OPINION AND ORDER Before the Court is Defendants’ Motion to Recalculate Fees on Remand (“Motion”). (Dkt. No. 602.) Also before the Court are two related motions for the disbursement of funds that are held in the Court’s registry (“Requests”). (Dkt. Nos. 611, 614.) Having considered these motions, the associated briefing, and the documents submitted in support thereof, the Court finds that the Motion should be GRANTED IN PART and that the Requests should similarly be GRANTED. I. BACKGROUND This Order addresses one main issue: to what extent the Court’s prior calculation of $471,220.38 in attorneys’ fees should be modified in light of the Fifth Circuit’s recent instructions. See CEATS, Inc. v. TicketNetwork, Inc., No. 24-40230, 2025 WL 2945804, at *10–12 (5th Cir. Oct. 17, 2025) (“[W]e observe that Ticket’s limited relief likely supports such a decrease to the fee award . . . .”). Pertinent background information for this issue is set forth below; additional background information can be found in the Fifth Circuit’s most recent decision. Id. at *1–5. More than a decade ago, Plaintiff CEATS, Inc. (“CEATS”) filed a patent infringement lawsuit against Defendants TicketNetwork, Inc. and Ticket Software, LLC (collectively, “Ticket”). The case eventually settled and Ticket obtained a license to use CEATS’s patents. Ticket subsequently filed the above-captioned lawsuit seeking declaratory relief as to the license, and CEATS filed counterclaims that Ticket breached the license. The Court entered a protective order, and the case proceeded to trial only on CEATS’s counterclaims. The jury ultimately found that $459,800 would compensate CEATS for Ticket’s breach of the license. (Id.)

Thereafter, CEATS breached the protective order of this case by mishandling Ticket’s confidential business information. (Dkt. No. 448 at 24, 25.) CEATS’s then-CEO, Milford Skane, had asked Dr. Brian Billett, his litigation consultant, to send him a confidential list of Ticket’s business affiliates that Ticket produced during discovery. Pursuant to the protective order, however, Mr. Skane was not permitted access to the confidential affiliate list. Nonetheless, Mr. Skane obtained a copy of it from his consultant and sent the affiliate list to Ticket’s CEO. Mr. Skane explained it was a “starting point” to revive the companies’ stalled settlement negotiations. (Id. at 8.) The Court sanctioned CEATS for its protective order violation. (Dkt. No. 477.) The Court determined that Mr. Skane had violated the protective order by improperly communicating

confidential materials and failing to take reasonable care with such materials. The Court further determined that CEATS had violated the protective order because Mr. Skane was acting within the scope of his employment. It ordered sanctions against CEATS in the form of attorneys’ fees and barred CEATS from suing or otherwise contacting any affiliate in Ticket’s affiliate list (“Litigation Bar”). CEATS appealed the sanctions ordered against it on two separate occasions. In the first appeal, the Fifth Circuit instructed this Court to recalculate the attorneys’ fees sanction. CEATS, Inc. v. TicketNetwork, Inc., 71 F.4th 314, 328 (5th Cir. 2023). It also vacated the Litigation Bar, explaining that such a bar required evidence of bad faith conduct. Id. The Court subsequently issued an order that included revised calculations and reinstated the Litigation Bar. (Dkt. No. 556.) This issue then went back up on appeal for the second time. In the second and most recent appeal, the Fifth Circuit did not find error in the Court’s calculation of $471,220.38 in attorneys’ fees. CEATS, 2025 WL 2945804, at *10–12. However,

the Fifth Circuit found that this Court improperly increased this calculation by 5% to adjust for time demands in rendering the legal services. Id. The Fifth Circuit reasoned that the calculated $471,220.38 value already accounted for such timing considerations, and that Ticket’s limited relief instead “likely supports . . . a decrease to the fee award.” Id. It set aside the Litigation Bar because it found that Ticket did not suffer substantial prejudice from CEATS’s discovery violation. Id. It then remanded the fee calculation issue for this Court “only” to determine to what extent the $471,220.38 in attorneys’ fees calculation should be decreased. Id. at *13. That is the issue which this Order addresses. II. LEGAL AUTHORITY “When a court awards attorney fees as part of a sanction under Rule 37, it generally . . . must use the familiar two-step lodestar process.” CEATS v. TicketNetwork, Inc., 71 F.4th 314, 326

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CEATS, INC. v. TICKETNETWORK, INC. and TICKET SOFTWARE, LLC, (E.D. Tex. 2026).

CEATS, INC. v. TICKETNETWORK, INC. and TICKET SOFTWARE, LLC (CEATS, INC. v. TICKETNETWORK, INC. and TICKET SOFTWARE, LLC) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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