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I imagine it would be easier to hit if the firm is indeed “busier”? Also depends on workflow and individual firm culture. 1850 at a firm that gives out work like candy and bills for everything can take significantly less time than 1850 at a firm where billable volume is incrementally earned and billing guidelines are more stringent.
Our target is 1850 but most of us in litigation bill over 2100 in a non major market - not sure that answers your question but we are busy.