In Robertson v. Fleetwood Travel Trailers of California, Inc. (2006) 144 Cal.App.4th 785, the court concluded, "the statutory language of section 1794, subdivision (d), is reasonably compatible with a lodestar adjustment method of calculating attorney fees" because "the lodestar adjustment method is based on actual, reasonable attorney time expended as the objective starting point of the analysis citation, it is compatible with this statutory provision."
The lodestar method is applicable to calculating attorney fees under section 1794, subdivision (d), the court reasoned, because "the lodestar adjustment method is the prevailing rule for calculation of statutory attorney fees unless the statute expressly indicates a contrary intent, and no such contrary intent is apparent ... ." (Robertson, supra, 144 Cal.App.4th at p. 821.)