On December 23, 2025, Justice Crane of the New York County Commercial Division issued a decision in Quartix Fin. Inc. v. KSH Brands LLC, 2025 NY Slip Op. 35193(U), reducing an attorneys’ fees award by ten percent because of block billing, explaining:
An award of reasonable attorneys’ fees is within the discretion of the court. To assess the reasonableness of attorneys’ fees, the court considers several factors, including the time and labor required, the difficulty of the issues involved, and the skill and effectiveness of counsel reducing the amount requested to eliminate work that was duplicative or was unnecessarily performed by an attorney, rather than a secretary or paralegal. The requesting party has the burden to prove the reasonableness of requested fees. The court may reduce fees that are excessive.
A fee award may also be reduced where there is block billing – the practice of lumping multiple charges together in a single billing entry. Specifically, courts may reduce requested fees when the use of block billing makes it makes it exceedingly difficult for the court to identify whether the amount of time spent on a particular task is reasonable.
Here, the court finds a reduction of 10% appropriate due to several instances of vague entries and block-billing. For example, in its finance sheet, plaintiff lists entries such as “re: new,” “litigation/docket review/ksks,” and pending “Bklyn action with Dror,” as billable tasks that it attempts to recover through this inquest. These tasks are examples of several entries that are either nonspecific, constitute block billing, or are completely unrelated to this action.
(Internal quotations and citations omitted).