What factors are considered to justify a request by counsel for a 30% award in a class action?

Here, counsel's requested 30 percent award exceeds the 25 percent benchmark. Factors that may justify departure from the benchmark include: (1) the result obtained; (2) counsel's efforts, experience, and skill; (3) the complexity of the issues; (4) the risks of non-payment assumed by counsel; (5) the reaction of the class; (6) non-monetary benefits, such as clarification of certain points of law; and (6) comparison with the lodestar. Vizcaino v. Microsoft Corp., 290 F.3d 1043, 1048-50 (9th Cir. 2002). Additional factors include whether counsel receives a disproportionate distribution of the settlement, whether the parties have agreed to a "clear sailing" arrangement, as here, whereby defendant will not object to counsel's request for fees, and whether any fees not awarded will revert to defendant rather than be added to the class fund. Bluetooth, 654 F. 3d at 947.

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1. The Result Obtained