federal litigation like the Laffey Matrix. It is also based on rates for the Washington metro area (which includes areas in West Virginia, Virginia, and Maryland, and Washington, DC), not just the District of Columbia. For these reasons, the U.S. Court of Appeals for the D.C. Circuit rejected the new matrix as reflecting rates for complex federal litigation in the District of Columbia in D.L. v. District of Columbia, 924 F.3d 585 (D.C. Cir. 2019). Many defendants have taken the position that the USAO Laffey Matrix or the new USAO Matrix should be used instead of the Legal Service Index (LSI) adjustment method presumably because the USAO Laffey Matrix and the new USAO Matrix produced lower hourly rates than the LSI-Adjusted Laffey Matrix. Some courts in the United States have used the USAO Laffey Matrix and the new USAO Matrix when awarding attorneys' fees under a fee-shifting statute, such as the Civil Rights Attorney's Fees Awards Act. LSI-Adjusted Laffey Matrix Based on Covington, some fee applicants have established the prevailing market rates using the Laffey Matrix adjusted by the Legal Services Component of the Consumer Price Index referred to as the Legal Services Index or the LSI. The LSI is provided monthly by the Bureau of Labor Statistics. The LSI-Adjusted Laffey Matrix is based on the 1989 update of the Laffey Matrix prepared following Save Our Cumberland Mountains. The LSI-Adjusted Laffey Matrix produces higher hourly rates than the USAO Laffey Matrix or the newer USAO Matrix. Some courts in the United States have awarded fees using the LSI-Adjusted Laffey Matrix. In December 2015, the D.C. Circuit affirmed such a fee award. Salazar v. District of Columbia, 809 F.3d 58 (D.C. Cir. 2015). The D.C. Circuit agreed with the district court that the evidence presented by plaintiffs demonstrates that "the LSI-Updated Laffey Matrix 'is probably a conservative estimate of the actual cost of legal services in this area'" (emphasis in original). It concluded that “[t]he District, neither below nor on appeal, rebuts this logic with relevant arguments.” The Court noted that the fact that other courts have applied the USAO Laffey Matrix “is not compelling.” Other courts have rejected the LSI-Adjusted Laffey Matrix, particularly for cases in the Washington-Baltimore region, and have based fee awards the USAO Laffey Matrix. See, e.g., Pleasants v. Ridge, 424 F. Supp. 2d 67, n.2 (D.D.C. 2006); Judicial Watch, Inc. v. BLM, No. 07-1570, 2008 U.S.