Wayman Fire Protection, Inc. v. Premium Fire & Security, LLC

CourtCourt of Chancery of Delaware
DecidedJune 27, 2014
DocketCA 7866-VCP
StatusPublished

This text of Wayman Fire Protection, Inc. v. Premium Fire & Security, LLC (Wayman Fire Protection, Inc. v. Premium Fire & Security, LLC) is published on Counsel Stack Legal Research, covering Court of Chancery of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wayman Fire Protection, Inc. v. Premium Fire & Security, LLC, (Del. Ct. App. 2014).

Opinion

COURT OF CHANCERY OF THE STATE OF DELAWARE

D ONALD F. PARSONS, J . R New Castle County Courthouse VICE CHANCELLOR 500 N. King Street, Suite 11400 Wilmington, Delaware 19801-3734

Date Submitted: April 3, 2014 Date Decided: June 27, 2014

Margaret M. DiBianca, Esq. Christopher A. Selzer, Esq. Young Conaway Stargatt & Taylor, LLP McCarter & English, LLP Rodney Square 405 N. King Street, 8th Floor 1000 N. King Street P.O. Box 111 Wilmington, DE 19801 Wilmington, DE 19899-0111

RE: Wayman Fire Protection, Inc. v. Premium Fire & Security, LLC Civil Action No. 7866-VCP

Dear Counsel:

On March 5, 2014, I issued a Post-Trial Opinion setting forth my findings of

fact and conclusions of law in this litigation. For the reasons set forth in the Post-

Trial Opinion, I concluded, among other things, that all Defendants 1 were jointly

1 My ruling, however, did not apply to Defendant Premium Power Services, LLC (“Premium Power”), who Plaintiff failed to prove was liable for any of its causes of action. Wayman Fire Prot., Inc. v. Premium Fire & Sec., LLC, [hereinafter, “Post-Trial Op.”], 2014 WL 897223, at *9 (Del. Ch. Mar. 5, 2014). As in the Post-Trial Opinion, all references to “Defendants” in this Letter Opinion are exclusive of Premium Power. Unless indicated otherwise, all defined terms have the same meaning as they did in the Post- Trial Opinion. Wayman Fire Protection, Inc. v. Premium Fire & Security, LLC Civil Action No. 7866-VCP June 27, 2014 Page 2

and severally liable under Delaware’s Misuse of Computer System Information

Act2 (the “Computer Misuse Act” or the “Act”) for procuring and utilizing

impermissibly certain of Wayman’s computer files. Pursuant to 11 Del. C. § 941,

which sets out remedies available for violations of the Computer Misuse Act, the

relief I awarded Wayman under the Act included “35% of the attorneys’ fees and

expenses it reasonably incurred in this litigation, net of the attorneys’ fees and

expenses I award[ed] . . . for Defendants’ contempt as to the Preliminary

Injunction order.”3

On March 19, 2014, counsel for Wayman submitted a proposed form of final

order and judgment. The proposed order requested an award of $17,300 for

nominal damages under 11 Del. C. § 941(b), $69,716.25 for unjust enrichment

under Section 941(c),4 and attorneys’ fees and costs of $374,128.12 under Section

941(e). By letter filed on April 2, 2014, Defendants seek a reduction in the amount 2 11 Del. C. §§ 931 to 941. 3 Post-Trial Op., 2014 WL 897223, at *31. 4 Wayman also requested an award of $67,190.41 in expenses for its retention of Digital Legal Services and Cornerstone Legal Consulting, LLC under Section 941(c). I discuss this aspect of Wayman’s proposed order further infra. Wayman Fire Protection, Inc. v. Premium Fire & Security, LLC Civil Action No. 7866-VCP June 27, 2014 Page 3

of Wayman’s requested attorneys’ fees and costs on the principal grounds that the

proposed amounts are disproportionate to the actual amount of money that was at

issue and the results that Wayman obtained.

For the following reasons, I conclude that the amount Wayman requests in

attorneys’ fees and costs under 11 Del. C. § 941(e) is unreasonable, primarily

because the amount sought is disproportionate to the result Wayman achieved after

trial.5 Therefore, in the exercise of my discretion, I reduce that amount by

5 To the extent Defendants objected to the amount of reimbursement Plaintiff requested for the expenses associated with Digital Legal or Cornerstone Legal Consulting, LLC, those objections are overruled. I consider the work of those consultants important to this litigation and the amount sought to be reasonable. Moreover, I note that, generally speaking, it is reasonable to infer that fees and expenses associated with computer consultants or experts likely will constitute a significant portion of the reasonable fees and expenses a plaintiff incurs in the course of prosecuting a computer misuse claim such as the one in this dispute. The other major component of those fees and expenses likely will be attorneys’ fees. Because in the Post-Trial Opinion I essentially awarded Wayman the entirety of the fees and expenses it incurred in connection with its retention of computer experts and the fees and expenses for computer experts attributable to the computer misuse claim would be subsumed within that amount, Wayman already will be reimbursed sufficiently for that aspect of his expenses and damages under the Act. Therefore, this Letter Opinion focuses on the other important component of Wayman’s reasonable computer fees and expenses, its computer misuse- related attorneys’ fees. Wayman Fire Protection, Inc. v. Premium Fire & Security, LLC Civil Action No. 7866-VCP June 27, 2014 Page 4

$174,128.12,6 and I award Wayman attorneys’ fees and costs in this matter in the

amount of $200,000.

It is “settled Delaware law” that a court must consider the factors stated in

Delaware Lawyers’ Rule of Professional Conduct (“DLRPC”) 1.5 in deciding the

reasonableness of attorneys’ fees.7 The factors identified in Rule 1.5(a) that are

relevant to this dispute include:

(1) the time and labor required, the novelty and difficulty of the questions involved, and the skill requisite to perform the legal service properly; (3) the fee customarily charged in the locality for similar legal services; (4) the amount involved and the results obtained; and (7) the experience, reputation, and ability of the lawyer or lawyers performing the services.

Defendants do not argue seriously that the amount of attorneys’ fees and

costs Plaintiff seeks for violation of the Computer Misuse Act is unreasonable

6 See Americas Mining Corp. v. Theriault, 51 A.3d 1213, 1255 (Del. 2012) (“The determination of any attorney fee award is a matter within the sound judicial discretion of the Court of Chancery.”). 7 Concord Steel, Inc. v. Wilm. Steel Processing Co., 2010 WL 571934, at *3 (Del. Ch. Feb. 5, 2010) (citing Mahani v. Edix Media Gp., Inc., 935 A.2d 242, 245-46 (Del. 2007)). Wayman Fire Protection, Inc. v. Premium Fire & Security, LLC Civil Action No. 7866-VCP June 27, 2014 Page 5

based on DLRPC 1.5(a)(3) or (7). Instead, they contend that the time and labor

Wayman’s counsel needed to spend to prove Wayman’s computer misuse claim

was minimal, and that the proposed award of attorneys’ fees and costs associated

with the computer misuse claim is disproportionate to the results Wayman

achieved after trial. Because these two arguments of Defendants are interrelated, I

address them together.

In post-trial briefing, Wayman sought an award of 80% of its reasonable

attorneys’ fees and costs under Section 941(e). In the Post-Trial Opinion, I

rejected this request as excessive, based on, among other things, the “shot-gun”

approach that Wayman used in this litigation, which caused both sides to spend

significant time investigating claims that proved to be without merit. Although I

reduced Plaintiff’s request for an award of 80% of its general attorneys’ fees and

expenses to 35%, I also recognized that the attorneys’ fees and expenses probably

would constitute the majority of the monetary relief Wayman obtained in this

litigation. At the time, however, there was no record evidence indicating how

much money Wayman had spent in attorneys’ fees and expenses. Wayman Fire Protection, Inc. v. Premium Fire & Security, LLC Civil Action No. 7866-VCP June 27, 2014 Page 6

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Mahani v. Edix Media Group, Inc.
935 A.2d 242 (Supreme Court of Delaware, 2007)
Americas Mining Corp. v. Theriault
51 A.3d 1213 (Supreme Court of Delaware, 2012)

Cite This Page — Counsel Stack

Bluebook (online)
Wayman Fire Protection, Inc. v. Premium Fire & Security, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wayman-fire-protection-inc-v-premium-fire-security-delch-2014.