to the main cause of action’ and ‘uniquely separable from the cause of action to be proved at trial’ ” Id. at 277, 114 S.Ct. 1483 (citations omitted). At least one court has drawn on this language in arguing amendments affecting FOIA’s fee-shifting provision may be applied retroactively. See Tax Analysts v. I.R.S., No. 96-2285, 2000 WL 689324 at *3 (D.D.C. March 31, 2000) (Kollar-Kotelly, J.) (finding that prior amendment which had potential to hinder attorney’s fee collection under FOIA would not have impermissible retroactive effect under Landgraf because “FOIA never guaranteed that complainants could recover attorney’s fees” as manifest in the circuit’s practice of discretionary awarding of attorney’s fees); cf. Barr Labs., Inc. v. Thompson, 238 F.Supp.2d 236, 253 (D.D.C. 2002) (<HOLDING>). When refusing to retroactively apply
holding a defendant is not vested with a right to be absent from trial holding statutory amendment was not impermissibly retroactive because plaintiff did not have sufficiently vested legal right under prior statutory language holding that sarbanesoxley is not retroactive and that neither the statutory language nor the legislative history of section 804 indicate that congress clearly favored retroactive application  holding legislatures retroactive amendment of statutory definition which rejected court interpretation did not violate separation of powers holding that the act is not retroactive