The Tenth Circuit stated that, to date, the court has not adopted a benchmark percentage for attorneys’ fees and declines to do so—instead, the court said that awards in a range of percentages may be reasonable.

The plaintiffs in the underlying case are shareholders in Array Biopharma. According to the opinion, those shareholders brought a federal securities class action claim against Array and its executives and alleged that the defendants made deliberate statements about a clinical trial resulting in significant shareholder losses.