The use of prohibitive fees is an obvious, and favorite, tactic used by public agencies wishing to discourage requests. On one occasion, for example, West Virginia University initially demanded payment of over eight hundred dollars in search fees and 'overhead costs' for producing a document a few pages long. The fee was subsequently waived after objections were raised. The obvious, and frequently successful, tactic of requesters who have been charged a clearly unreasonable fee has sometimes been simply to refuse to pay the bill or, if advance payment was required, to demand and sue for a refund. Few agencies would be interested in defending such a seemingly losing cause, particularly if the requester makes known her intention to seek an award of attorneys' fees from the agency.