Anyone who hoped that commercial litigation might help law firms weather the recession was surely disappointed last year.

That’s judging by the recoveries Nat­ional Law Journal affiliate VerdictSearch counted among its Top 100 Verdicts of 2009. Commercial verdicts, including breach-of-contract recoveries, fell from $1.4 billion in 2008 to $421 million last year. Fraud recoveries plummeted by nearly 70% to $561.3 million. Intellectual property litigation saw an increase — from $2.2 billion to $2.6 billion. But that picture was distorted by a single massive recovery: Centocor Ortho Biotech Inc.’s $1.67 billion verdict against Abbott Laboratories in the Eastern District of Texas. Absent that result, patent judgments would have declined significantly.