To obtain a private attorney general fee award, the applicant must show, among other things, that “the necessity and financial burden of private enforcement … are such as to make the award appropriate.” Private enforcement is a “necessity” unless a public prosecutor or other government agency stands ready to enforce the right. Here, the trial court abused its discretion in holding the entire requirement satisfied by lack of public enforcement. Instead, it should also have separately weighed whether the on-speculative financial benefits the fee applicant expected to gain from the litigation roughly equally the cost of the litigation.