Sterling, Winchester & Long, LLC, “the LLC” appeals from the trial court’s order entering a default judgment against it. The LLC asserts the trial court erred by striking its pro se answer based on the trial court’s conclusion that an LLC must be represented by counsel, by failing to give it an opportunity to hire counsel and file an amended answer, and by failing to hold an evidentiary hearing on the amount of damages owed. Finding no merit in these enumerations, we affirm. 1. The LLC contends that the Supreme Court’s requirement that corporations be represented by an attorney in courts of record should not be applied to limited liability corporations. See Eckles v. Atlanta Technology Group , 267 Ga. 801, 805 2 485 SE2d 22 1997. We find no merit in this contention because we recently held that limited liability corporations must be represented by attorneys in courts of record. Winzer v. EHCA Dunwoody, LLC , 277 Ga. App. 710, 713-714 3 627 SE2d 426 2006. Because of the similarities between limited liability companies and corporations, we conclude that the rationale and holding of Eckles should, and does, apply to limited liability companies. Like a corporation, a limited liability company is a business entity that protects its members from personal liability for business debts. Like a corporation, a limited liability company can act only through its agents. Like a corporation, allowing a limited liability company to be represented in court by a nonattorney agent would permit the practice of law by an unlicensed layman who is not subject to the discipline of the court. And like those who accept the benefits of incorporation, those who accept the benefits of a limited liability company must also accept its burdens, including the need to hire counsel. Citations and footnotes omitted. Id. at 713.
2. The LLC argues, in the alternative, that any holding requiring limited liability corporations to be represented by counsel should not be applied retroactively. In Findley v. Findley , 280 Ga. 454 1 629 SE2D 222 2006, the Georgia Supreme Court outlined the criteria to be used to determine if a judicial decision should be applied retroactively: A judicial decision announcing a new rule is retroactive unless the decision itself expressly makes it a matter of pure or selective prospectivity or, after examining whether retroactive application would adversely affect operation of the new rule and weighing the inequity imposed by retroactive application, we subsequently conclude application of the new rule would cause unjust results to those who justifiably relied on the former state of the law. In so doing, the criteria set out in Chevron Oil Co. v. Huson , 404 U S 97 92 SC 349, 30 LE2d 296 1971 may be employed. Id. at 461. In Chevron Oil , the U. S. Supreme Court outlined the following criteria to be used when determining whether a judicial decision should be applied prospectively: