2. Background and Procedural History
The alleged trade-secret scheme
PRD had entered into a development arrangement with Magnetic Drive Development and Venture LLC concerning a large, water-cooled adjustable-speed drive unit. Flux Drive, Inc. was to design the unit for sale in China, Hong Kong, and Singapore. Rong, an engineer, acted as a technical liaison between Magnetic Venture and PRD and attended meetings at the plaintiffs’ Washington offices.
The plaintiffs alleged that Rong subsequently approached Sparks, a senior design engineer associated with the plaintiffs, to obtain confidential technology. They claimed that Rong transmitted a Master Services Agreement under which Sparks supplied trade secrets to PRD and that the Rong Defendants helped finance this activity.
The defendants disputed that characterization. Rong described his role as facilitating communications and providing translation assistance. Wang stated that the defendants’ financial involvement consisted of a $23,000 bridge loan to Sparks while PRD’s payment was delayed. Sparks repaid the loan in less than a month.
The plaintiffs submitted declarations, deposition excerpts, emails, and banking records. Sparks testified that Rong was someone he would “supposedly report to.” That testimony supported a preliminary inference of supervision. The evidence did not, however, explain how the communications, agreement, or loan enabled the alleged theft.
The claims and the three appeals
The plaintiffs asserted fraudulent concealment, misappropriation under the Colorado Uniform Trade Secrets Act (“CUTSA”), violation of the federal Defend Trade Secrets Act (“DTSA”), civil conspiracy, unjust enrichment, and conversion.
- Jurisdictional dismissal: On July 11, 2025, the district court dismissed the Rong Defendants under Rule 12(b)(2). The plaintiffs filed an initially premature appeal because claims against other defendants remained pending.
- Initial fees and certification: The district court awarded $114,663.11 under Colorado Revised Statutes § 13-17-201 and certified the dismissal under Rule 54(b). An amended final judgment was entered on December 11, 2025.
- Supplemental fees: The defendants sought additional fees incurred after their original application. The district court awarded $68,990.50, excluding a requested administrative charge.
The two fee awards totaled $183,653.61. The appellate court’s affirmance did not determine whether trade-secret theft actually occurred or resolve the claims against the remaining defendants.
4. Analysis and Precedents Cited
A. The Principal New Holding: Finality of Fees Following Rule 54(b) Certification
Ordinarily, an order resolving the case against only some defendants is not immediately appealable. Rule 54(b) creates a limited exception: a district court may enter final judgment as to particular claims or parties if it expressly determines that there is no just reason for delay.
The opinion distinguishes two questions. First, was the jurisdictional dismissal properly certified? Second, did that certification permit appellate review of the related fee award without waiting for the remaining litigation?
Certification of the dismissal
Okla. Tpk. Auth. v. Bruner, 259 F.3d 1236, supplied the controlling framework. A district court must expressly determine both that the certified order is final and that review should not await resolution of the remaining claims. Finality receives de novo review; the no-just-reason-for-delay determination receives abuse-of-discretion review. The appellate court must examine certification even when the parties do not contest it.
The dismissal conclusively removed the Rong Defendants from this action. Moreover, the jurisdictional questions were sufficiently distinct from the underlying merits to justify immediate review. The court relied on the persuasive reasoning of Butler v. Daimler Trucks N.A., LLC, which recognized that certification of personal-jurisdiction dismissals can resolve threshold issues early and potentially avoid a second trial.
Lewis v. B.F. Goodrich Co., 850 F.2d 641, established that a notice of appeal filed before Rule 54(b) certification can ripen when certification subsequently occurs. B. Willis, C.P.A., Inc. v. BNSF Ry. Corp. reinforced that subsequent finality can cure a premature notice. These authorities allowed the court to hear the dismissal appeal rather than reject it because of its original timing.
Finality of the collateral fee award
The court expressly identified an unresolved Tenth Circuit question: whether a fee award associated with a Rule 54(b) judgment is final while other claims remain pending.
It adopted the reasoning of Johnson v. Orr, 897 F.2d 128, a Third Circuit decision. Once the district court determines that a judgment should be immediately final, its collateral consequences—including an associated fee award—should not remain nonfinal merely because other defendants are still litigating.
Yost v. Stout supported the premise that attorney fees are generally collateral to the merits. The court considered it anomalous to permit an immediate appeal of the underlying judgment while postponing review of the fee consequence attached to that judgment.
Certification nevertheless does not make every fee-related order appealable. Under Phelps v. Washburn Univ. of Topeka, 807 F.2d 153, a fee award becomes final only when the amount is fixed. Because the district court had awarded a specific $114,663.11, that requirement was satisfied.
Scope of the new rule: A related, quantified collateral fee award can be reviewed under 28 U.S.C. § 1291 despite unresolved claims against other defendants. The opinion does not make an unquantified entitlement ruling final, dispense with proper Rule 54(b) certification, or declare all fee orders immediately appealable.
B. Personal Jurisdiction Requires Both Deliberate Contacts and a Connection to the Claims
The governing statutory and constitutional framework
The existence of a federal DTSA claim did not itself authorize nationwide personal jurisdiction. Following Trujillo v. Williams, the court asked whether an applicable service-of-process provision authorized jurisdiction and whether exercising that authority would satisfy due process.
The DTSA contains no nationwide-service provision applicable here. Mission Measurement Corp. v. Blackbaud, Inc. supplied persuasive support for that conclusion. Federal Rule of Civil Procedure 4(k)(1)(A) therefore directed the court to Colorado jurisdictional law.
Under Archangel Diamond Corp. v. Lukoil, Colorado’s long-arm statute extends to the constitutional limit. The statutory and constitutional inquiries consequently merged.
Int'l Shoe Co. v. Washington, 326 U.S. 310, provided the foundation: defendants must have minimum contacts with the forum, and jurisdiction must comport with traditional notions of fair play and substantial justice. Trujillo v. Williams and Shrader v. Biddinger supplied the two requirements central here:
- The defendants must purposefully direct relevant activities toward the forum.
- The claims must arise out of or relate to those forum contacts.
The opinion mentioned Helicopteros Nacionales v. Hall only as background concerning general jurisdiction. The plaintiffs did not pursue general jurisdiction on appeal, and the court decided only specific jurisdiction.
The preliminary evidentiary burden
Several precedents explain why the plaintiffs received favorable treatment of genuine factual disputes without receiving acceptance of unsupported conclusions:
- OMI Holdings v. Royal Ins. Co. of Can. placed the jurisdictional burden on the plaintiffs and explained that, after adequate minimum contacts are established, defendants may attempt to show that jurisdiction would nevertheless be unreasonable.
- Wenz v. Memery Crystal characterized the preliminary burden as light: without an evidentiary hearing, competent written materials need establish only a prima facie jurisdictional case. Allegations contradicted by defense affidavits require evidentiary support rather than repetition.
- Rambo v. Am. S. Ins. Co. required acceptance of uncontroverted allegations and resolution of conflicting affidavit evidence in the plaintiffs’ favor.
- FDIC v. Oaklawn Apartments likewise permitted decision on affidavits and other written materials, with factual conflicts resolved favorably to the plaintiffs at this stage.
- Dudnikov v. Chalk & Vermilion Fine Arts, Inc., drawing on Bell Atl. Corp. v. Twombly, limited that favorable treatment to plausible, nonconclusory, nonspeculative factual allegations.
Accordingly, the court did not demand proof of liability. It required a factual basis for exercising authority over these particular defendants in Colorado.
Why purposeful direction was established
The plaintiffs identified repeated communications with Sparks, an alleged supervisory relationship, and the transfer of $23,000 into his Colorado bank account. The court held that these contacts satisfied the first component of the jurisdictional inquiry at the preliminary stage.
Dudnikov v. Chalk & Vermilion Fine Arts, Inc. supplied the tort-context purposeful-direction framework, focusing on intentional conduct aimed at the forum and knowledge concerning the location of injury. The court rejected the defendants’ attempt to dismiss their dealings categorically as brief, noncommercial favors.
Sparks’s qualified testimony about reporting to Rong was sufficient to support a preliminary inference of supervision. Under Hafen v. Howell, equivocation can affect evidentiary weight without rendering testimony mere speculation where the witness has personal knowledge. The court therefore did not treat the words “supposedly” and “supposed to be” as automatically disqualifying.
Nor did the contacts have to establish a continuous business relationship. Burger King Corp. v. Rudzewicz, relying on McGee v. Int'l Life Ins. Co., recognized that even one act may support jurisdiction if it creates a substantial forum connection. Rambo v. Am. S. Ins. Co. similarly acknowledged that a single communication can sometimes suffice.
These authorities mattered because the defendants emphasized the limited duration of their Colorado dealings. The court treated the nature and significance of the contacts—not simply their frequency—as important.
Why the connection to the alleged injuries was missing
The decisive deficiency concerned relatedness. Evidence that Rong communicated with Sparks or acted for PRD did not explain how those activities facilitated misappropriation.
The Master Services Agreement was an independent-contractor arrangement between Sparks and PRD. It did not mention the plaintiffs, their technology, or Rong. The plaintiffs identified no contractual provision or accompanying communication that explained how the agreement enabled the theft.
The bridge loan presented the same problem. Although the transfer was undisputed, the plaintiffs did not provide record support for their appellate assertion that the money financed a workstation and software used to steal trade secrets. They also failed to substantiate that the defendants knew of, directed, or controlled that use. The complaint’s statement that financing aided unlawful concealed activity was conclusory.
The following precedents explain the court’s insistence on this additional connection:
- Newsome v. Gallacher directed attention to whether the claimed injury resulted from the defendant’s forum-related activities. It supported the distinction between showing involvement in a business relationship and showing a connection between that involvement and the asserted harm.
- Walden v. Fiore required the relevant relationship to arise from the defendant’s own contacts with the forum itself. A relationship with a person who happens to live there is not enough standing alone.
- Anzures v. Flagship Rest. Grp. applied that principle to reject jurisdiction based on random, fortuitous, or attenuated connections created through another person’s forum affiliation.
- Dental Dynamics, LLC v. Jolly Dental Grp., LLC emphasized the need for an adequate connection between the forum and the underlying controversy.
- XMission, L.C. v. Fluent LLC required an adequate link between the forum and the claims actually asserted. Extrinsic evidence may support jurisdiction, but it cannot substitute a materially different claim for the one pleaded.
Smith v. Sperling, cited through Newsome v. Gallacher, helped preserve the distinction between jurisdictional analysis and adjudication of the merits. The court was not deciding whether the plaintiffs had ultimately proved misappropriation. It was deciding whether their factual presentation connected the alleged injury to the defendants’ Colorado activities.
Important limitation: Although the opinion frequently describes the missing connection in causal terms, it also repeatedly uses the established “arise out of or relate to” formulation. It should not be read as announcing a universal strict-causation test. The plaintiffs failed to establish an adequate connection under the facts presented.
Because minimum contacts were incomplete, the court did not reach the separate reasonableness inquiry under OMI Holdings v. Royal Ins. Co. of Can., Burger King Corp. v. Rudzewicz, and Int'l Shoe Co. v. Washington.
C. No Automatic Right to a Jurisdictional Evidentiary Hearing
The plaintiffs argued that the district court should have held an evidentiary hearing. The court rejected that challenge principally because the opening brief did not develop it adequately.
The argument was not barred simply because the plaintiffs had not requested the hearing below. The defendants had requested one, and the district court expressly decided that it would not materially assist. Under Tesone v. Empire Mktg. Strategies, an issue expressly considered and resolved below may be reviewed even when the appellant did not originally raise it.
Nevertheless, the plaintiffs failed to identify particular evidence the district court improperly rejected or facts a hearing could have established that would supply the missing jurisdictional connection.
The plaintiffs’ reliance on Dutcher v. Matheson and Breakthrough Mgmt. Grp., Inc. v. Chukchansi Gold Casino & Resort did not establish a mandatory-hearing rule. Those decisions concerned jurisdictional discovery, a different procedural question. Dutcher v. Matheson nevertheless supplied a useful prejudice principle: a party must explain how the absence of particular facts harmed its position, not merely complain that further fact development was unavailable.
FDIC v. Oaklawn Apartments also showed why the plaintiffs’ position was unpersuasive. A pretrial evidentiary hearing would have required proof of jurisdictional facts by a preponderance of the evidence, rather than the more favorable prima facie showing applicable to the written record. The plaintiffs had not identified additional proof capable of satisfying even the lower threshold.
The conditional request for leave to amend was separately rejected as moot. The plaintiffs requested that relief only if the dismissal remained nonfinal; proper Rule 54(b) certification eliminated that condition. Phelps v. Hamilton supplied the general mootness principle. This was not a broad holding restricting amendment under Rule 15 after every jurisdictional dismissal.
D. Statutory Trade-Secret Claims Can Sound in Tort for Colorado Fee Shifting
Why Colorado’s fee statute applied in federal court
Colorado Revised Statutes § 13-17-201 requires reasonable defense fees when an action for injury occasioned by another’s tort is dismissed on the defendant’s Rule 12(b) motion before trial.
Jones v. Denv. Post Corp. established that attorney-fee statutes are substantive law in the Tenth Circuit and that the forum state’s substantive law applies to pendent state claims. It also supported application of the Colorado provision following a federal Rule 12(b) dismissal.
Weidner v. Doe provided additional persuasive support for treating the statute as applicable in federal proceedings despite its reference to Colorado procedural rules. The court expressly treated that unpublished decision as persuasive rather than binding, consistent with United States v. Ellis.
Xlear, Inc. v. Focus Nutrition, LLC supplied the review framework: fee decisions and amounts generally receive abuse-of-discretion review, but statutory interpretation and underlying legal analysis receive de novo review. The appellate standard remains a matter of federal procedure even when entitlement arises under state law.
Why “statutory” did not mean “non-tort”
The plaintiffs argued that CUTSA and DTSA were the complaint’s central claims and therefore made the action statutory rather than tort-based. The court rejected that proposed distinction.
Castro v. Lintz supplied the “essence of the action” test for complaints combining tort and non-tort theories. US Fax L. Ctr., Inc. v. Henry Schein, Inc. established that predominantly tort-based actions remain covered despite accompanying non-tort claims and that the statute does not exclude federal statutory torts.
The essential distinction is between the source of a legal duty and the nature of the wrong alleged. A statute may define a tort. Enacting a statutory remedy for misappropriation does not automatically turn the underlying wrongful appropriation into a non-tort claim.
Three additional authorities supported that characterization:
- DeGette v. Mine Co. Rest., Inc. recognized statutory trade-secret theft as a tort.
- Sticky.io, Inc. v. Martingale Software, LLC explained that misappropriation, interference, and fraud remain torts notwithstanding reliance on federal statutes.
- Multimedia Games, Inc. v. WLGC Acquisition Corp. characterized misappropriation of trade secrets and confidential information as essentially tortious.
Accordingly, the court held that this action predominantly sounded in tort. That conclusion does not require treating every unjust-enrichment claim, or every statutory cause of action, as a tort in all circumstances.
Questions left undecided
The plaintiffs also attempted to argue that § 13-17-201 excludes purely economic injuries, is displaced by CUTSA’s fee provision, or is preempted by the DTSA. Those theories were not preserved below, and the plaintiffs did not seek plain-error review.
The court therefore did not resolve those statutory-interaction questions on their merits. The decision should not be cited as a substantive rejection of DTSA preemption or CUTSA displacement arguments properly preserved in another case.
E. Reasonable Fees, Billing Judgment, and Artificial Intelligence
The lodestar framework
Robinson v. City of Edmond required the court to begin with the lodestar: reasonable hours multiplied by a reasonable hourly rate. The resulting figure carries a presumption of reasonableness.
Case v. Unified Sch. Dist. No. 233 placed the documentation burden on the fee applicants and required judicial scrutiny of billing judgment. Unnecessary, duplicative, inadequately documented, or irrelevant work may be excluded. Relevant considerations include complexity, reasonable litigation strategies, and work generated by the opposing party’s conduct.
The magistrate judge reviewed detailed records, found tenth-of-an-hour timekeeping without block billing, identified reductions made by counsel, and considered additional work caused by amendment of the complaint. The hourly rates were supported by comparable Colorado market rates.
The plaintiffs’ generalized objections did not identify particular double-billed entries or improper partner-level tasks. Under Anchondo v. Anderson, Crenshaw & Assocs., LLC, unsupported assertions of excessive hours do not establish an abuse of discretion. That decision also rejected the proposition that experienced lawyers must work without compensation whenever a task does not demand their full expertise.
This reasoning does not exempt staffing and task allocation from review. Rather, it requires a concrete objection capable of showing why the particular fee request is unreasonable.
Why alleged AI efficiencies did not justify a reduction
The plaintiffs argued that counsel’s use of AI and online research tools should have reduced compensable hours. The court accepted that technology can reduce research time, but rejected an automatic reduction unsupported by billing evidence.
Arbor Hill Concerned Citizens Neighborhood Ass'n v. Cnty. of Albany supplied the useful analogy: electronic research may reduce the hours needed for manual research and therefore lower the lodestar. The relevant question remains how much reasonable work the particular matter required.
The opinion also emphasized that AI does not eliminate verification duties:
- Amarsingh v. Frontier Airlines, Inc. involved sanctions for using generative AI to prepare an appellate brief without verifying whether cited cases existed.
- Wadsworth v. Walmart Inc. found Rule 11 violations arising from filings containing AI hallucinations.
- Coomer v. Lindell recognized that Rule 11 applies to AI-assisted legal work.
These authorities explained why technological assistance does not make all subsequent research and checking unnecessary. The plaintiffs identified no evidence that the actual hours claimed were excessive because of AI use.
The resulting principle is evidentiary, not a technological exemption: AI may affect reasonable hours, but its use does not automatically establish overbilling. Conversely, the decision does not permit charging for hypothetical manual hours that were never worked or protect inefficient work from ordinary lodestar scrutiny.
F. Supplemental Fees Remained Available After the Initial Award
Finality did not exhaust the district court’s authority
The plaintiffs argued that a final, sum-certain fee judgment prevented supplementation unless the district court had reserved jurisdiction. The court found no supporting rule.
Glass v. Pfeffer had affirmed supplemental fees for collateral fee litigation after an initial award. Stroup v. United Airlines, Inc. illustrated the use of Rule 54(d) for a later supplemental application. Hutchinson v. Beckworth, an unpublished decision used persuasively, rejected the conclusion that a pending appeal deprived the district court of authority to consider supplemental fees.
These authorities establish the distinction between the finality necessary for appeal and the continuing ability to decide a proper collateral fee request. The court did not authorize supplementation without regard to timing, prior adjudication, or reasonableness.
The supplemental application was timely
Rule 54(d)(2)(B)(i) ordinarily requires a fee motion within fourteen days after judgment. The relevant amended final judgment was entered on December 11, 2025. The fourteenth day was December 25, a legal holiday, so Rule 6 extended the deadline to December 26. The defendants filed that day.
Newmont U.S.A. Ltd. v. Ins. Co. of N. Am. informed the court’s distinction between issuance of the December 10 order and entry of the December 11 judgment. The calculation turned on entry of the relevant judgment, not simply the date the court announced its ruling.
Silence about additional fees was not an implicit denial
The defendants’ reply supporting the original fee motion mentioned another $48,658.29. The magistrate judge nevertheless addressed only the $114,663.11 requested in the original motion.
The district court explained that it had not adjudicated the additional request. Under the local rule, a motion had to be filed separately rather than embedded in a reply. The defendants had also indicated that a separate supplemental motion would follow.
Baker ex rel. Thomas v. Gen. Motors Corp. supplied the decisive preclusion principle: issue preclusion concerns matters actually litigated and resolved by a valid final judgment. Because the additional fees had not been resolved, the initial award did not preclude their later consideration.
The holding is therefore record-specific. It does not allow a party to relabel fees already denied on their merits as a supplemental request.
Fees incurred obtaining or defending fees
The plaintiffs’ arguments against recovery for collateral fee litigation and non-frivolous appeals were waived. As an alternative merits response, the court relied on Dubray v. Intertribal Bison Coop., which permitted appellate fees under § 13-17-201 for successfully defending an initial fee award.
This reasoning distinguishes mandatory statutory fee shifting from sanctions. Recovery did not depend on proving that the plaintiffs’ fee challenge or appeal was frivolous. The recoverable work still had to fall within the applicable fee entitlement and be reasonable.
G. The Magistrate-Judge Review Error Was Harmless
The district court applied the “clearly erroneous or contrary to law” standard associated with Rule 72(a) to objections concerning the supplemental award. That was incorrect.
Rule 54(d)(2)(D) permits referral of a fee motion to a magistrate judge as if it were a dispositive pretrial matter. Rule 72(b)(3) therefore required de novo determination of properly objected-to portions of the recommendation.
The error did not require reversal for two reasons. First, the district court independently relied on its earlier determination that § 13-17-201 applied. Bishop v. Smith explained the law-of-the-case doctrine and the limited circumstances supporting departure from an earlier legal ruling, including clear error producing manifest injustice. The plaintiffs did not adequately challenge that independent ground.
Second, the district court stated that the result would be the same under de novo review, and the appellate court’s own examination confirmed that the preserved challenges failed. Applying Quint v. Vail Resorts, Inc., the court treated the review-standard error as harmless.
The opinion thus preserves the de novo-review requirement while refusing a remand that would not affect the outcome. It does not approve routine use of Rule 72(a) for fee recommendations.
H. Preservation and Briefing Rules Materially Shaped the Decision
Several arguments failed because of when or how they were presented. These procedural rulings are essential to understanding the limits of the substantive holdings.
| Precedent |
Role in the opinion |
| Morales-Fernandez v. INS |
States the firm waiver rule: failure to make timely objections to a magistrate judge’s recommendation ordinarily waives appellate review of factual and legal questions. |
| United States v. B.N.M. |
Requires sufficiently specific objections that direct the district court to the actual disputed issues. Summaries and general gestures toward favorable allegations are insufficient. |
| Hicks v. Franklin |
Recognizes that a party can waive or forfeit reliance on the firm waiver rule itself. Because the defendants did not invoke it for certain objections, the court elected to reach those issues. |
| Richison v. Ernest Grp., Inc. and United States v. Olano |
Supply the framework for unpreserved arguments. Failure to raise a theory below ordinarily forfeits it; failure also to seek plain-error review on appeal can end consideration of that theory. |
| United States v. McBride |
Supports declining review altogether where an appellant neither preserved an issue nor argues plain error. This affected the economic-loss, statutory-displacement, preemption, administrative-charge, and collateral-fee theories. |
| United States v. Clay, United States v. Woodmore, and Bronson v. Swensen |
Require developed opening-brief arguments supported by analysis, authority, and record references. They supported rejection of the hearing challenge and the inadequately developed attack on the law-of-the-case ground. |
| Star Fuel Marts, LLC v. Sam's E., Inc. |
Bars reliance on an argument first developed in a reply brief. It applied to the plaintiffs’ attempted mandatory-hearing theory. |
| Marshall v. Chater |
Treats issues first raised in objections to a magistrate judge’s recommendation as waived. It supported rejection of newly presented objections, including the supplemental-fee argument concerning the nature of post-judgment work. |
The practical lesson is that presenting a broad objection such as “fees are unreasonable” does not necessarily preserve every later theory of unreasonableness. Likewise, challenging statutory entitlement on one ground does not preserve distinct preemption or displacement arguments.
5. Potential Impact
Appellate practice in multiparty litigation
The new finality holding clarifies the treatment of collateral fees after a partial final judgment. Parties should separately track the certified merits judgment, the order fixing fees, and any supplemental award. Continuing litigation against other defendants does not necessarily postpone review of the quantified fee award.
The decision also confirms that a later Rule 54(b) certification can cure a premature merits appeal. That mechanism should not replace careful attention to finality, because certification still requires the district court’s express findings and remains subject to appellate scrutiny.
Trade-secret and coordinated-misconduct litigation
Plaintiffs suing remote intermediaries must do more than identify communication, supervision, or financing. They should explain how the relevant emails, contractual provisions, instructions, transfers, or other acts connect the selected forum to the alleged misuse of confidential information.
The opinion is especially important where one alleged participant resides in the forum but others act elsewhere. A resident defendant’s presence does not itself establish jurisdiction over everyone alleged to have participated in the same scheme. The court did not, however, announce a comprehensive rule governing every possible conspiracy-based jurisdiction theory.
Financial exposure following threshold dismissals
In covered Colorado tort actions, a successful jurisdictional dismissal can generate substantial fee liability without any merits determination or finding that the lawsuit was frivolous. Characterizing a trade-secret claim as statutory does not, by itself, avoid that consequence.
The reserved preemption and displacement questions remain significant. Future litigants wishing to contest the interaction between § 13-17-201 and trade-secret-specific fee provisions must present those arguments at the proper stage.
Technology-sensitive fee disputes
The AI discussion favors evidence-based scrutiny rather than assumptions about automation. Fee applicants should document actual work and verification efforts; opponents should identify concrete excess, duplication, or inefficiency. Neither technological optimism nor technological suspicion substitutes for examination of billing records.
Supplemental applications and judicial administration
Courts retain authority to address proper supplemental fee requests without an express reservation of jurisdiction. But applicants must respect applicable deadlines and local motion requirements, and courts must distinguish genuinely unadjudicated fees from requests already resolved.