Hollywood star Rebel Wilson may receive a smaller payout for legal costs than she had hoped, following her defamation fight against magazine publisher Bauer Media.
The Pitch Perfect actor was in September awarded a record $4.5 million after Bauer was found to have painted her as a serial liar in a series of articles in May 2015.
Wilson spent close to $1.5 million on the 22-day trial and wants the majority of her costs repaid.
It is expected she will have at least 80 per cent of those costs, or $1.123 million, repaid.
Her barrister Renee Enbom argued she should get at least $1.3 million back, asking Victorian Supreme Court Justice John Dixon to assess and award a "gross sum costs order" rather than go through protracted arguments before a dedicated costs court.
The amount includes fees of $9000 per day for high-profile barrister Matthew Collins QC and the costs of a security guard during the proceedings.
Ms Enbom previously said Wilson and Bauer Media were arguing over a difference of between $100,000 and $200,000.
She said Wilson may have to wait until the end of 2018 before recovering her fees if the matter went to a costs court, costing more than another $100,000 to finalise.
She also argued that given Bauer's previous conduct during proceedings, the process was likely to be drawn-out and expensive.
However on Thursday, Justice Dixon refused the application, saying that to award a gross sum was a "rare event".
"First, although a purpose of awarding a gross sum costs order may be to avoid delay and expense, it cannot be assumed that in a particular case, such an assessment will be more time and cost efficient than taxation," he said in his written judgment.
"Nor can it be assumed that a gross sum assessment will be simpler."
He expressed concerns that if he ordered a gross sum, it could be "arbitrary" based on the material before him.
The court has previously been told that Wilson offered to settle the defamation matter for $200,000 before it went to trial, but Bauer knocked back the offer.
Bauer Media plans to appeal against the record-breaking $4.5 million payout, with the matter listed for later this month.