You will be given a definition of a task first, then some input of the task.
In this task, you will be shown a prompt from a judicial decision and multiple holding statements derived from citations following text in a legal decision.  Holdings represent the governing legal rule when the law is applied to a particular set of facts. There are five answer choices for each citing text. The correct answer is the holding statement that corresponds to the citing text. You should write an incorrect option. Even though there exist multiple wrong answers, we only need a single wrong answer. There is a <HOLDING> token in the position of the citing text prompt where the holding statement was extracted.

a mechanism for obtaining large attorney’s fee awards in cases with de minimis returns for the client and society in general. Furthermore, the prospect of a fee award can skew attorneys’ incentives when confronted with settlement offers that would more than compensate their clients, but that fall short of the large fees already incurred. These concerns are most prevalent in cases such as this, where recovery of private damages, rather than the vindication of constitutional rights, is the primary purpose. While it is Congress’ duty to re-shape fee-shifting provisions to alleviate these concerns, it is this Court’s duty to determine a reasonable fee in light of the de minimis victory achieved in this case. See Hensley v. Eckerhart, 461 U.S. 424, 436, 103 S.Ct. 1933, 76 L.Ed.2d 40 (1983) (<HOLDING>). I. BACKGROUND After a jury trial before this 
 Holding statements: (A) recognizing that the third factor permanence is the most important (B) holding that the most critical factor in the analysis of a reasonable fee is the degree of success obtained (C) holding that status as a prevailing party does not by itself entitle a plaintiff to attorneys fees rather the most critical factor in determining a fee awards reasonableness is the degree of success obtained emphasis added (D) holding that the quantity of relief obtained as compared to what the plaintiff sought to achieve are key elements in determining the degree of success (E) holding that the fee applicant bears the burden of showing that  an adjustment is necessary to the determination of a reasonable fee 
Output:
recognizing that the third factor permanence is the most important