The class action alleging consumer fraud and other claims against Volkswagen due to its use of software designed to cheat emission tests and deceive regulators resulted in the establishment of a funding pool of more than $10 billion.  Class counsel indicated at the time of settlement approval that they would not seek more than $324 million in fees.  Ultimately, counsel sought less – they submitted a fee application for $167 million, plus $8 million in costs.  On March 17, 2017, the district court granted the petition.  In re Volkswagen “Clean Diesel” Mktg., Sales Practices, and Prod. Liab. Litig., MDL No. 2672 (N.D. Cal. Mar. 3, 2017).  After reviewing Ninth Circuit law, which permits a benchmark for attorneys’ fees in common fund actions of 25%, the district court addressed the result obtained (the awarded fee was less than 2%), which was notable in light of the short duration of the case, the litigation risk, the benefit of non-monetary relief, reactions from class and objectors, and other factors.  The court also applied a lodestar crosscheck and calculated a lodestar of $63.5 million, with a multiplier of 2.63.  Based on all of these factors, the court found the request reasonable and approved the request in its entirety.