The pervasive use of billable hours by lawyers in the U.S. is a fairly recent phenomenon. Historically lawyers billed at flat rates, or on percentage bases, or based on ‘value billing’ for ‘services rendered’. The ABA began promoting hourly billing in 1958, arguing that as lawyers’ time was their “sole expendable asset”, they needed to better record and charge for it. However, state and local bar associations published minimum fee schedules for many years, until these were struck down on anti-trust grounds in Goldfarb v. Virginia State Bar (1975). Following that decision, large firms generally switched to billable hours, which became the norm by the late 1970s. Billable hour expectations have grown greatly during that time; in 1958 the ABA considered 1,300 billable hours per year to be a reasonable full-time figure, although today large firms generally consider 1,800 -2,300 or more to be billable hour minimums.