This is because the Wisconsin Consumer Act "depends upon private lawsuits for enforcement and . . . private enforcement of the Act will be unsuccessful unless prevailing consumers can expect adequate attorney fee awards." Clark v. Aetna Fin. Corp., 115 Wis.2d 581, 591, 340 N.W.2d 747 (Ct.App. 1983). ¶ 6 Although an attorney fee award is mandatory, WIS. STAT. § 425.308 leaves determination of the amount to the circuit court's discretion.

This is because the Wisconsin Consumer Act "depends upon private lawsuits for enforcement and . . . private enforcement of the Act will be unsuccessful unless prevailing consumers can expect adequate attorney fee awards." Clark v. Aetna Fin. Corp., 115 Wis.2d 581, 591, 340 N.W.2d 747 (Ct.App. 1983). ¶ 6 Although an attorney fee award is mandatory, WIS. STAT. § 425.308 leaves determination of the amount to the circuit court's discretion.

Western National relies on cases in which fees are awarded to a prevailing party under statutes that provide for an award of "reasonable attorney fees." See, e.g., Standard Theatres, Inc. v. StateDept. of Transp., 118 Wis.2d 730, 349 N.W.2d 661 (1984) ("litigation expenses" under Wis. Stat. § 32.28(1) are defined to include "reasonable attorney . . . fees necessary to prepare for or participate in actual or anticipated [condemnation] proceedings"); Clark v. AetnaFin. Corp., 115 Wis.2d 581, 340 N.W.2d 747 (Ct.App. 1983) (Wisconsin Stat. § 425.308(1) provides for a "reasonable amount for attorney's fees" for prevailing consumer in consumer transaction). Western National asserts that our standard of review on this issue is the same as that we employed in deciding whether an insured may recover attorney fees as a component of damages — de novo.