On October 31, 2022, Justice Crane of the New York County Commercial Division issued a decision in Supply Co., LLC v. Hardy Way, LLC, 2022 NY Slip Op. 33722(U), cutting a fee award because counsel used block billing, explaining:
Next, the invoices attached to Hardy Way’s motion are rife with block billing. While block billing does not render a fee request per se unreasonable, here, a reduction of the fee request to account for block billing is well within the court’s discretion. The invoices include a number of examples of block billing which make it impossible to determine the reasonability of fees, including, for example, an entry which combines coordination of service with drafting a motion to dismiss, and an entry which combines internal firm meetings with drafting a mediation statement. Considering the frequent use of block billing, the court further reduces the requested fee award by 15%.
(Internal citations omitted).