Fee petition mechanics · Updated July 2026
California Song-Beverly used consumer goods attorney fee petition mechanics: used good purchase date as primary Welch anchor, Civ. Code § 1794(d) mandatory attorney fees
California Song-Beverly Consumer Warranty Act — Implied Warranty on Used Consumer Goods civil enforcement (Civ. Code § 1795.5 — applies to the sale at retail of used consumer goods, defined under § 1791.3 as goods that have been previously sold to and used by a consumer; § 1795.5(b) implied warranty duration: coextensive with any accompanying express warranty but no less than 30 days and no more than 90 days; § 1795.5(b)(2) price-based implied warranty schedule when no express warranty accompanies the goods: [A] 30 days if retail price less than $500; [B] 60 days if retail price $500–$999.99; [C] 90 days if retail price $1,000 or more; § 1791.1(a) implied warranty of merchantability: the goods must pass without objection in the trade, be fit for the ordinary purposes for which they are used, be adequately contained and packaged, and conform to any promises made on the label) solos billing hourly on mandatory attorney fees — in actions where the primary Welch temporal anchor is the DATE OF USED CONSUMER GOOD PURCHASE (the date the consumer purchased the used vehicle, appliance, electronic device, or other consumer good from a retail seller at retail price; this date is the ONLY primary anchor in the entire fee-petition-mechanics series in a USED CONSUMER GOOD RETAIL PURCHASE DATE — the date of purchase on the sales receipt, the retail installment sales contract, or the dealer invoice, set by the retail seller's own point-of-sale calendar entirely outside the buyer-plaintiff attorney's scheduling control; the purchase date is not a court filing, not a government complaint, not any document the plaintiff attorney authors or schedules — it is the retail transaction date stamped by the seller's own point-of-sale system; the purchase date determines the start of the § 1795.5(b) statutory implied warranty period [30/60/90 days depending on retail price], making the defect-within-warranty-period determination — the central factual question in every § 1795.5 case — measured backward from the first complaint of the defect to the purchase date; DISTINCT from Song-Beverly new goods [Civ. Code §§ 1791–1795.8: new vehicle lemon law; primary Welch anchor = DATE OF NEW VEHICLE PURCHASE; § 1793.2(d)(2) mandatory repurchase/replacement; new vehicle express warranty duration governed by manufacturer's written warranty — not by a price-based statutory schedule]; DISTINCT from Magnuson-Moss Warranty Act § 2303 [federal written warranty requirements; no implied warranty duration schedule for used goods; federal § 2310(d)(2) mandatory attorney fees but Dague no-multiplier applies: City of Burlington v. Dague 505 U.S. 557 (1992)]; DISTINCT from vehicle dealer fraud [Veh. Code § 11711, tier_jjj: RISC execution at dealership F&I office — covers affirmative misrepresentation in the sales process, not post-purchase warranty failures]; DISTINCT from Rees-Levering [Civ. Code § 2983: motor vehicle installment sales finance terms, not implied warranty duration]; § 1794(d): 'If the buyer prevails in an action under this section, the buyer shall be allowed by the court to recover as part of the judgment a sum equal to the aggregate amount of costs and expenses, including attorney's fees based on actual time expended, determined by the court to have been reasonably incurred by the buyer in connection with the commencement and prosecution of such action' — MANDATORY attorney fees to prevailing buyer [plaintiff-only; no bilateral fee risk]; § 1794(b)(1): buyer may recover restitution — replacement or refund; § 1794(b)(2): consumer may recover consequential damages [rental car costs, repair costs incurred during warranty period]; § 1794(e): civil penalty up to two times actual damages for willful violation; Ketchum v. Moses 24 Cal.4th 1122 (2001) Ketchum multiplier eligible in California Superior Court; Ketchum/Dague split: § 1794(d) California Superior Court Ketchum eligible vs. Magnuson-Moss § 2310(d)(2) federal district court Dague no-multiplier; Hensley task-level segregation required between California § 1794(d) hours and federal Magnuson-Moss § 2310(d)(2) hours; Hensley v. Eckerhart 461 U.S. 424 (1983) lodestar from DATE OF USED CONSUMER GOOD PURCHASE; Missouri v. Jenkins 491 U.S. 274 (1989) fees-on-fees) — generate three billing gaps driven by § 1795.5 implied warranty duration calculation and defect-within-warranty-period analysis and purchase date advisory calls on the retail seller's point-of-sale calendar, the concurrent BAR vehicle repair enforcement calendar and DMV dealer licensing enforcement calendar and CFPB/FTC Magnuson-Moss Warranty Act enforcement calendar, and the § 1794(d) mandatory attorney fee petition and § 1794(e) civil penalty assessment and Ketchum/Dague split Hensley segregation advisory calls: § 1795.5 implied warranty duration calculation and defect-within-warranty-period analysis and purchase date advisory calls (7 clients × 2 calls × 42 min × 55% untracked ≈ 5.39 hrs = $1,617–$2,695/year at $300–$500/hr), BAR vehicle repair enforcement and DMV dealer licensing enforcement and CFPB/FTC Magnuson-Moss concurrent calendar advisory calls (6 clients × 3 calls × 44 min × 55% ≈ 7.26 hrs = $2,178–$3,630/year), and § 1794(d) mandatory attorney fee petition and § 1794(e) civil penalty assessment and Ketchum/Dague split Hensley segregation advisory calls (5 clients × 2 calls × 44 min × 55% ≈ 4.03 hrs = $1,210–$2,017/year). For a solo California Song-Beverly § 1795.5 used goods enforcement practice, the annual billing gap from advisory call underlogging is $5,005–$8,342.
TL;DR
ClaimHour captures every § 1795.5 implied warranty duration calculation and defect-within-warranty-period analysis and purchase date advisory call that starts the § 1794(d) fee documentation period from the DATE OF USED CONSUMER GOOD PURCHASE, every concurrent BAR automotive repair enforcement and DMV dealer licensing enforcement and CFPB/FTC Magnuson-Moss calendar advisory call on external proceedings calendars entirely outside the attorney's scheduling control, and every § 1794(d) mandatory attorney fee petition and § 1794(e) civil penalty and Ketchum/Dague split and Hensley segregation advisory call on the post-judgment fee petition calendar — passively, no timer, no audio, no call contents. $29–$59/mo. No PMS required.
§ 1795.5 implied warranty duration calculation and defect-within-warranty-period analysis: calls on the retail seller's point-of-sale calendar
The DATE OF USED CONSUMER GOOD PURCHASE — the date the consumer purchased the used vehicle, appliance, electronic device, or other consumer good from a retail seller at retail price — is the primary Welch temporal anchor for § 1794(d) attorney fee billing documentation. This date is the ONLY primary anchor in the fee-petition-mechanics series in a USED CONSUMER GOOD RETAIL PURCHASE DATE. It is the Hensley lodestar start for three structural reasons: (1) § 1795.5(b) implied warranty period start: the 30/60/90-day implied warranty period runs from the date of purchase — the warranty period begins on the purchase date and expires on the date calculated by adding the applicable statutory duration to the purchase date; every defect-within-warranty-period determination is measured by reference to the purchase date; (2) § 1795.5(b) price-based duration determination: the applicable warranty duration — 30, 60, or 90 days — is determined by the retail price as of the purchase date, not by any event the plaintiff attorney schedules or controls; the retail price is set by the seller's own point-of-sale system on the seller's own sales calendar; a used vehicle purchased for $12,000 carries a 90-day implied warranty [retail price $1,000 or more] running from the purchase date; (3) § 1794(d) mandatory fee petition lodestar start: the Hensley lodestar must cover all advisory hours from the purchase date through the implied warranty period, demand, litigation, and fee petition; all § 1795.5 advisory calls from the moment the buyer retains counsel — which occurs when the buyer first identifies the defect and seeks legal advice, typically within days of discovering the defect within the warranty period — through the entire litigation and fee petition are compensable hours running from the purchase date under Missouri v. Jenkins 491 U.S. 274 (1989) fees-on-fees.
Three initial advisory call types generate untracked billing from the purchase date: (1) § 1795.5(b) implied warranty duration calculation and defect-within-warranty-period analysis advisory — arrives when the consumer retains Song-Beverly § 1795.5 enforcement counsel (§ 1795.5(b) duration checklist: [a] retail price determination: what was the actual retail price paid on the purchase date? [the price on the sales receipt, not the listed price]; is the good a vehicle [additional DMV and Veh. Code § 11713.3 analysis required], an appliance, an electronic device, or another consumer good?; [b] express warranty check: did the seller provide any written express warranty with the used good? if yes, the implied warranty duration is coextensive with the express warranty duration subject to the 30-day minimum and 90-day maximum cap; if the express warranty was, say, 6 months, the implied warranty is capped at 90 days; [c] defect manifestation date: on what date did the buyer first observe the defect? [the defect manifestation date must fall within the § 1795.5(b) implied warranty period measured from the purchase date]; [d] defect-within-warranty-period timeline: subtract the purchase date from the defect manifestation date; is the difference less than 30 days [for goods under $500], less than 60 days [for goods $500–$999.99], or less than 90 days [for goods $1,000+]?; [e] § 1791.1(a) merchantability analysis: does the defect establish that the good failed to pass without objection in the trade [was the defect known in the used market for this type of good?], failed to be fit for the ordinary purposes for which such goods are used [could the defect cause the good to fail at its primary function?], or failed to conform to promises made on any label?; [f] § 1795.5(c) notice of defect: the buyer must provide the seller a reasonable opportunity to repair the defect; the notice obligation is triggered within the warranty period; was timely notice given?; 42–48 min per call); (2) Purchase date documentation and warranty period calculation advisory — arrives when assembling the § 1795.5 case file (purchase date documentation sources: to establish the DATE OF USED CONSUMER GOOD PURCHASE, the attorney must obtain: [a] the original sales receipt showing the purchase date, the retail price, and the seller's identity [the retail price on the sales receipt determines the applicable warranty duration under § 1795.5(b)(2)]; [b] if a vehicle: the Retail Installment Sales Contract [RISC] showing the contract execution date and the cash selling price [the cash selling price on the RISC is the retail price for § 1795.5(b)(2) purposes]; [c] the dealer invoice or order acknowledgment showing the sale date; [d] DMV vehicle registration records showing the registration transfer date [corroborates purchase date]; [e] any express warranty documentation provided at the time of sale [determines whether § 1795.5(b) implied warranty is coextensive with an express warranty or falls under the price-based duration schedule]; purchase date significance for § 1794(d): the purchase date is the date from which the § 1795.5(b) warranty period is calculated; in cases where the seller disputes the purchase date [e.g., the seller argues the purchase occurred after repairs were made, reducing the warranty period], the purchase date documentation is both a factual and legal issue; prejudgment interest under Civ. Code § 3287 runs from the date the right to damages became certain — which may be the date of the seller's final refusal to repair or replace within the warranty period; 42–48 min per call); (3) § 1794(b) remedies analysis and § 1794(e) willful violation assessment advisory — arrives when evaluating the seller's response to the warranty claim (§ 1794(b)(1) restitution: the buyer is entitled to the return of the purchase price plus any charges the buyer is obligated to pay under any related sales or lease contract, minus the value of use of the good prior to the defect; restitution calculation requires knowing the purchase price [from the purchase date], the charges paid [from financing documents dated at purchase], and the value-of-use offset [calculated from miles driven from purchase date to first defect manifestation]; § 1794(b)(2) consequential damages: rental car costs during repair period; costs of repairs the buyer incurred during the warranty period before the seller acknowledged the defect; lost time from work necessitated by dealing with the defective good; all consequential damages flow from the defect-within-warranty-period period measured from the purchase date; § 1794(e) civil penalty: up to two times actual damages for willful violation; willfulness analysis: did the seller know of the defect before the sale? did the seller deny the warranty claim based on pretextual inspection findings? did the seller represent that the good complied with § 1795.5 in its sales advertising while knowing the good had pre-existing defects?; § 1794(e) civil penalty doubles the § 1794(b) restitution and consequential damages — a willfulness finding from the purchase date through the warranty denial dramatically increases the § 1794(d) fee petition value; 42–48 min per call). At 55% untracked: 7 clients × 2 calls × 42 min × 55% = 323.4 min / 60 = 5.39 hours = $1,617–$2,695/year at $300–$500/hr.
BAR automotive repair enforcement calendar and DMV dealer licensing enforcement calendar and CFPB/FTC Magnuson-Moss concurrent enforcement calendar: calls on the external proceedings calendars
A California Song-Beverly § 1795.5 used goods implied warranty case typically involves three concurrent external proceedings calendars that run entirely outside the buyer-plaintiff attorney's scheduling control: the California Bureau of Automotive Repair (BAR) enforcement calendar [BAR licenses automotive repair dealers under Bus. & Prof. Code §§ 9880–9889 and may cite dealers who sell vehicles with pre-existing defects while warranting them as meeting implied warranty standards], the California DMV dealer licensing enforcement calendar [DMV licenses vehicle dealers under Veh. Code §§ 11700–11733 and may revoke licenses of dealers who systematically sell vehicles with undisclosed defects], and the CFPB/FTC Magnuson-Moss Warranty Act enforcement calendar [FTC primary enforcement authority for Magnuson-Moss § 2301 et seq.; CFPB supervisory authority over Buy Here Pay Here used car financing]. The BAR enforcement calendar runs on BAR's own investigation, citation, and OAH hearing timeline. The DMV enforcement calendar runs on DMV's own administrative hearing schedule at OAH. The CFPB/FTC enforcement calendar runs on each agency's own docket entirely outside the plaintiff attorney's scheduling control. Each calendar generates advisory calls the plaintiff attorney cannot schedule, time, or anticipate. Ketchum v. Moses 24 Cal.4th 1122 (2001). PLCM Group Inc. v. Drexler 22 Cal.4th 1084 (2000). Hensley v. Eckerhart 461 U.S. 424 (1983) lodestar from purchase date. Missouri v. Jenkins 491 U.S. 274 (1989) fees-on-fees.
Three concurrent external proceedings calendar advisory call types generate untracked billing: (1) BAR automotive repair enforcement calendar advisory — the most direct California state enforcement calendar in used vehicle § 1795.5 practice (BAR licensing and enforcement authority: BAR licenses automotive repair dealers under Bus. & Prof. Code § 9880 et seq.; BAR may inspect a dealer's pre-sale vehicle inspection records [the Dealer's Report of Sale and pre-delivery inspection checklist] to determine whether the dealer conducted any pre-sale safety and mechanical inspection; BAR citation proceedings: if BAR finds that the dealer sold a vehicle with pre-existing defects that the dealer's own pre-sale inspection should have identified — defects that manifested within the § 1795.5(b) implied warranty period — BAR may issue a citation under Bus. & Prof. Code § 9884.7 [failure to disclose a known defect in a written estimate]; BAR citation records are subpoenable in the plaintiff's § 1795.5 civil action and may establish that the seller knew of the defect at or before the purchase date [establishing willfulness for § 1794(e) civil penalty]; BAR Arbitration Program: while the BAR Arbitration Program under Veh. Code § 3286 and Civ. Code § 1793.22 applies to new vehicle lemon law cases, BAR receives and logs consumer complaints about used vehicle sales that involve warranty issues; BAR complaint intake calendar runs on BAR's own scheduling entirely outside plaintiff attorney's control; BAR complaint status updates arrive on BAR's own timeline; 44–50 min per call); (2) DMV dealer licensing enforcement calendar advisory — arrives when the dealer's pattern of selling defective used goods raises license revocation issues (DMV dealer licensing enforcement under Veh. Code §§ 11700–11733: DMV issues and revokes vehicle dealer licenses; Veh. Code § 11705 grounds for revocation include: [a] fraud or fraudulent representation in connection with a sale [§ 11705(a)(1)]; [b] making any false statement or concealing any material fact in an application [§ 11705(a)(2)]; [c] violating any provision of the Vehicle Code relating to the sale of vehicles [§ 11705(a)(9)]; Veh. Code § 11713.3(i): dealer prohibited from 'sell[ing] a used vehicle... without disclosing to the buyer, in writing, prior to the sale' any known safety recall that has not been remedied — undisclosed safety defects manifesting within the § 1795.5(b) implied warranty period may also violate § 11713.3; DMV OAH revocation calendar: DMV files Accusation against dealer → dealer requests OAH hearing → OAH ALJ schedules hearing on OAH's own calendar [6–18 months after filing] → ALJ issues proposed decision → DMV Director adopts, modifies, or rejects proposed decision → dealer exhausts judicial review [writ of mandate in Superior Court]; DMV OAH hearing is a public proceeding; testimony from DMV investigators about the dealer's pre-sale inspection practices, the dealer's knowledge of the defect, and the dealer's prior history of warranty complaints is admissible in the plaintiff's § 1795.5 civil action; DMV revocation records [particularly any findings about the dealer's pre-sale inspection protocols] are probative of whether the dealer's warranty denial was willful under § 1794(e); DMV OAH calendar runs entirely outside plaintiff attorney's scheduling control; 44–50 min per call); (3) CFPB/FTC Magnuson-Moss Warranty Act enforcement calendar advisory — arrives when the case involves a Buy Here Pay Here dealer or a nationwide used goods retailer with a written warranty program (FTC Magnuson-Moss enforcement authority: FTC has primary enforcement authority over the Magnuson-Moss Warranty Act [15 U.S.C. § 2301 et seq.] under its FTC Act § 5 authority; FTC may investigate used goods retailers who issue written warranties violating § 2303 [failure to designate warranty as 'full' or 'limited'] or § 2304 [failure to meet minimum standards for full warranties]; FTC enforcement actions against used vehicle dealers for warranty disclosure violations generate public consent orders that establish industry-wide warranty disclosure practices; FTC consent order records are admissible in the plaintiff's California § 1795.5 case as evidence that the seller knew of its warranty obligations yet failed to comply; CFPB auto lending supervisory authority: CFPB has supervisory authority over Buy Here Pay Here dealers under the Consumer Financial Protection Act [12 U.S.C. § 5515] for BHPH dealers who extend consumer credit; CFPB examinations of BHPH dealers may produce supervisory findings about warranty disclosure practices in connection with used vehicle financing; CFPB examination findings are confidential but may be referenced in CFPB enforcement actions that become public; Ketchum/Dague split critical for concurrent Magnuson-Moss claims: if the plaintiff brings both California § 1795.5 [state; § 1794(d) Ketchum eligible] and federal Magnuson-Moss § 2310(d)(2) [federal; Dague no-multiplier] claims in California Superior Court under 28 U.S.C. § 1367 supplemental jurisdiction or directly in federal district court, Hensley task-level segregation is required between California § 1794(d) hours and federal § 2310(d)(2) hours; the Ketchum multiplier is available only for the California § 1794(d) track; hours advising on CFPB/FTC Magnuson-Moss compliance [federal regulatory] must be segregated from state § 1795.5 implied warranty hours for the § 1794(d) fee petition; CFPB/FTC calendar runs entirely outside plaintiff attorney's scheduling control; 44–50 min per call). At 55% untracked: 6 clients × 3 calls × 44 min × 55% = 435.6 min / 60 = 7.26 hours = $2,178–$3,630/year at $300–$500/hr.
§ 1794(d) mandatory attorney fee petition advisory: calls on the post-judgment fee petition calendar
Civ. Code § 1794(d) provides mandatory attorney fees to the prevailing buyer: 'If the buyer prevails in an action under this section, the buyer shall be allowed by the court to recover as part of the judgment a sum equal to the aggregate amount of costs and expenses, including attorney's fees based on actual time expended, determined by the court to have been reasonably incurred by the buyer in connection with the commencement and prosecution of such action.' The § 1794(d) fee provision is plaintiff-only mandatory — the defendant seller is NOT entitled to attorney fees if it prevails [no bilateral fee risk]; this is DISTINCT from bilateral fee statutes like CUTSA [Civ. Code § 3426.4, tier_iii] and Civ. Code § 789.3(c) [tier_jjj]. The § 1794(d) fee petition requires a Hensley lodestar from the DATE OF USED CONSUMER GOOD PURCHASE through the implied warranty period, demand, litigation, and fee petition, with Ketchum multiplier analysis for the California § 1794(d) track and Hensley task-level segregation from any concurrent federal Magnuson-Moss § 2310(d)(2) track. Ketchum v. Moses 24 Cal.4th 1122 (2001). PLCM Group Inc. v. Drexler 22 Cal.4th 1084 (2000). Hensley v. Eckerhart 461 U.S. 424 (1983). Missouri v. Jenkins 491 U.S. 274 (1989) fees-on-fees.
Two § 1794(d) post-judgment advisory call types generate untracked billing: (1) § 1794(d) fee petition component assembly and § 1794(e) civil penalty damages calculation advisory — arrives at judgment (§ 1794(d) fee petition components: [a] § 1795.5(b) implied warranty duration calculation and defect-within-warranty-period analysis advisory hours [from purchase date]; [b] purchase date documentation and warranty period calculation advisory hours [from purchase date]; [c] § 1794(b) remedies analysis and § 1794(e) willful violation assessment advisory hours; [d] BAR automotive repair enforcement calendar monitoring hours; [e] DMV dealer licensing enforcement calendar monitoring hours; [f] CFPB/FTC Magnuson-Moss concurrent calendar monitoring hours [Hensley segregation: California § 1794(d) hours vs. federal Magnuson-Moss § 2310(d)(2) hours]; [g] § 1794(e) civil penalty litigation hours [willfulness trial preparation; BAR/DMV enforcement record discovery]; [h] Missouri v. Jenkins 491 U.S. 274 (1989) fees-on-fees: hours expended preparing the § 1794(d) fee petition itself are compensable; § 1794(d) damages calculation: § 1794(b)(1) restitution [purchase price minus value-of-use offset] plus § 1794(b)(2) consequential damages [rental car, repair costs, lost wages] plus § 1794(e) civil penalty [up to two times actual damages for willful violation] plus § 1794(d) attorney fees and costs; § 1794(e) willfulness factors: did the seller's pre-sale inspection records show knowledge of the defect? did the seller's warranty denial cite defects that predated the sale? did the seller's warranty claim file show a pattern of denying valid § 1795.5 claims on the same vehicle model?; 44–50 min per call); (2) Ketchum multiplier analysis and Hensley task-level segregation advisory — arrives at fee petition (Ketchum four-factor multiplier for California § 1794(d) fee petition in California Superior Court: [a] implied warranty duration uncertainty — whether the defect would manifest within the 30/60/90-day § 1795.5(b) window was unknown at the purchase date; the defect-within-warranty-period question was entirely unresolved at inception; [b] defect-before-sale uncertainty — whether the defect predated the purchase and was known to the seller [§ 1794(e) willfulness] was unknown at the purchase date; establishing seller knowledge requires BAR/DMV enforcement record discovery that may take months; [c] § 1794(e) civil penalty uncertainty — whether the seller's warranty denial was willful [doubling damages] was unknown at inception; civil penalty litigation adds substantial contested liability; [d] replacement/refund/repair uncertainty — whether buyer's ultimate remedy would be § 1794(b)(1) restitution, § 1794(b)(2) consequential damages, or continued repair attempts under § 1795.5(c) was unknown at inception; Ketchum multiplier calculation: the court selects a multiplier based on the above factors [typically 1.5–3.0] and applies it to the lodestar [hours × prevailing market rate from PLCM Group]; Hensley task-level segregation for concurrent Magnuson-Moss cases: California § 1794(d) hours [state court; Ketchum multiplier applied] must be recorded separately from federal Magnuson-Moss § 2310(d)(2) hours [federal court; City of Burlington v. Dague 505 U.S. 557 (1992) no multiplier]; hours advising on BAR enforcement [exclusively California regulatory] are California § 1794(d) track hours with no federal Magnuson-Moss counterpart; hours advising on FTC Magnuson-Moss enforcement [exclusively federal regulatory] are federal § 2310(d)(2) track hours requiring Hensley segregation; hours advising on DMV dealer license revocation may be allocable to both state and federal tracks depending on whether the DMV enforcement findings are used to prove willfulness under § 1794(e) [state] or warranty disclosure violations under Magnuson-Moss § 2303 [federal]; PLCM Group 22 Cal.4th 1084 (2000) prevailing market rate for California consumer warranty practice; Missouri v. Jenkins 491 U.S. 274 (1989) fees-on-fees; 44–50 min per call). At 55% untracked: 5 clients × 2 calls × 44 min × 55% = 242 min / 60 = 4.03 hours = $1,210–$2,017/year at $300–$500/hr.
How ClaimHour fits California Song-Beverly § 1795.5 used consumer goods practice
California Song-Beverly § 1795.5 used consumer goods solos billing hourly on mandatory attorney fees — with § 1795.5 implied warranty duration calculation and defect-within-warranty-period analysis and purchase date advisory calls arriving when consumers retain Song-Beverly enforcement counsel (DATE OF USED CONSUMER GOOD PURCHASE = primary Welch anchor; the ONLY primary anchor in the fee-petition-mechanics series in a USED CONSUMER GOOD RETAIL PURCHASE DATE — the date on the sales receipt, retail installment sales contract, or dealer invoice, set by the retail seller's own point-of-sale calendar entirely outside the buyer-plaintiff attorney's scheduling control; § 1795.5(b) price-based implied warranty duration schedule [30/60/90 days]; § 1794(d) mandatory attorney fees to prevailing buyer; no bilateral fee risk), BAR automotive repair enforcement calendar advisory calls on BAR's own investigation and citation timeline entirely outside plaintiff attorney's scheduling control, DMV dealer licensing enforcement calendar advisory calls on DMV's own OAH administrative hearing calendar entirely outside plaintiff attorney's scheduling control, CFPB/FTC Magnuson-Moss enforcement calendar advisory calls on each agency's own supervisory and enforcement docket entirely outside plaintiff attorney's scheduling control, and § 1794(d) mandatory attorney fee petition and § 1794(e) civil penalty and Ketchum/Dague split and Hensley task-level segregation from purchase date advisory calls arriving at judgment — and if your § 1794(d) lodestar documentation must satisfy the Hensley contemporaneous-record standard from the DATE OF USED CONSUMER GOOD PURCHASE through the implied warranty period, seller warranty denial, BAR/DMV/CFPB/FTC concurrent enforcement monitoring, and fee petition, ClaimHour was built for that gap.