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

That’s judging by the recoveries that 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 percent 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.