In Raider v. Sunderland, download file, the Chancery Court awarded a bonus payment to the individual plaintiff, to be deducted from class counsel’s fees. The court allocated an amount to the class representative based on a careful consideration of the special expertise that this individual brought to the case, and which expertise was needed in the case, however, the court also noted the serious policy concerns that circumscribed the amount awarded and also provided a rationale that would make it difficult for the average individual to qualify for such a bonus. The court was careful not to base the award on the benefit to the class (even though there was a large benefit), due to policy concerns that might give rise to abuse in future cases.