But even more importantly, the Ninth Circuit holds today that the value of this referral is recoverable in quantum meruit.
Admittedly, this was a good case in which to so hold. Moreover, the case is ostensibly limited to so holding under Nevada law -- though Judge Nelson's opinion isn't based on any peculiar content of that legal system and will likely be seen as extending more broadly.
So this is a very good holding for attorneys who do referrals. Yet more money for doing very little work.