In AirDoctor, LLC v. Xiamen Qichuang Trade Co., the US Court of Appeals for the Ninth Circuit held that Federal Rule of Civil Procedure 54(c) does not prohibit awarding actual damages in a default judgment to a party that sought actual damages in its pleadings in an amount to be determined at trial.
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FRCP 54(c) Does Not Prohibit Awarding Actual Damages in a Default Judgment: Ninth Circuit
