MacDermid Printing Solutions LLC v. Cortron Corp

Filing 501

ORDER. Consistent with the Second Circuit's decision in MacDermid Printing Solutions, LLC v. Cortron Corp., 833 F.3d 172 (2d Cir. 2016), the Court has recalculated compensatory and punitive damages as set forth in the attached. The Cou rt previously ordered the parties to file memoranda concerning attorneys' fees and offer-of judgment interest within fourteen days of this order. (ECF No. 498.) The Court hereby vacates that order and issues the following order instead: Within 21 days of today, the parties shall meet and confer with regard to attorneys' fees and attempt to reach agreement as to the total amount of fees the Court should include in the revised judgment. Should the parties agree, they sha ll file a joint statement so indicating and providing the agreed-upon amount. If no agreement is reached, each side shall file within 21 days of today, a memorandum indicating: (i) Whether fees should be allocated and, if so, in what manner a nd amount, (ii) Any discovery or other proceedings necessary to effectuate such an allocation, (iii) Whether each party agrees that offer-of-judgment interest is not currently recoverable (i.e., based on the corrected compensatory and punitive damage s and the correct amount of attorneys' fees), (iv) Whether and to what extent MacDermid is entitled to fees relating to the appeal; if MacDermid seeks such fees, it shall submit proof of its appellate fees and expenses in the same manner and for mat as its earlier fee submission, (ECF No. 469), (v) Whether MacDermid should be allowed to recover fees for any further proceedings needed to ascertain the correct amount of attorneys' fees, and (vi) A proposed calculation of post-judgment interest, setting forth the applicable interest rate under 28 U.S.C.§ 1961. Signed by Judge Michael P. Shea on 4/18/2017. (Howard, H.)

UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
MACDERMID PRINTING SOLUTIONS, LLC
Plaintiff,
v.
No. 08-cv-1649 (MPS)

CORTRON CORPORATION
Defendant.

Ruling on Calculation of Compensatory and Punitive Damages Following Remand

I.

Introduction
In this long-running commercial dispute involving claims of breach of contract and

alleged violations of trade secrets, unfair trade practices, and antitrust laws, the U.S. Court of
Appeals for the Second Circuit reversed the antitrust portion of a $64 million judgment entered
after a jury verdict in favor of MacDermid Printing Solutions, LLC (“MacDermid”).
MacDermid Printing Solutions LLC v. Cortron Corp., 833 F.3d 172 (2d Cir. 2016). The Court
of Appeals remanded the case to this Court, with a directive “to recalculate damages in a manner
consistent with” its opinion. (ECF No. 492 at 1.) The parties now dispute what this directive
means as it applies to this case. According to MacDermid, it means that I must restore a portion
of the jury’s damages award on an unfair trade practices claim that I had eliminated, post-verdict
and pre-appeal, as duplicative of the damages award on the antitrust claims, to account for the
fact that the Second Circuit has reversed the judgment on the antitrust claims. (ECF No. 500 at
6.) MacDermid argues that liability for unfair trade practices is broader than liability for antitrust
violations and, thus, the Circuit’s opinion reversing the judgment on the antitrust claims is no
obstacle to reinstating the jury’s original damages award on the unfair trade practice claims –
which can no longer be considered duplicative. (Id. at 13-15.) Defendant Cortron Corp.
1

(“Cortron”) counters that (1) the Circuit’s mandate prohibits a restoration of damages on the
unfair trade practices claim, which was not part of the appeal, (2) MacDermid’s acceptance of
my post-verdict remittitur of the damages on the unfair trade practices claim bars reviving those
damages now, (3) MacDermid’s arguments are barred by the doctrine of judicial estoppel, and
(4) MacDermid’s argument fails on the merits, because the unfair trade practices claim was
merely derivative of the antitrust claims. (ECF No. 499 at 6.) I agree with Cortron’s first two
arguments and do not address the remaining arguments. I therefore recalculate compensatory
and punitive damages in this action as follows:

Compensatory Damages
Breach of Contract
$4,112,970.00
CUTPA
$0.00
CUTSA
$3,790,939.00
Computer Crime
$29,970.00
Total
$7,933,879.00
Punitive Damages
Breach of Contract
$0.00
CUTPA
$100,000.00
CUTSA
$3,790,939.00
Computer Crime
$0.00
Total
$3,890,939.00
Total Compensatory and Punitive
$11,824,818.001
Damages

1

This calculation is identical to the one I docketed in October 2016. (ECF No. 493.) Because
MacDermid objected to my calculation of CUTPA damages at that time (ECF No. 494), I
ordered the parties to file briefs to address MacDermid’s argument regarding restoration of a
portion of the CUTPA damages award. (ECF No. 496.) Neither party objected to any other
aspect of the calculation. I also extended the time for the parties to address attorneys’ fees and
interest until 14 days after this ruling. (ECF No. 498.)
2

II.

Background
The facts of this case are set forth in the Second Circuit’s opinion, familiarity with which

is presumed. A brief procedural history follows. In September 2008, MacDermid filed suit
against Cortron in state court, alleging claims for breach of contract and for violations of state
and federal antitrust laws, the Connecticut Uniform Trade Secrets Act, Conn. Gen. Stat. §§35-50
to 35-58 (“CUTSA”), the Connecticut computer crime statute, Conn. Gen. Stat. §§ 53a-251, 52570b, and the Connecticut Unfair Trade Practices Act, Conn. Gen. Stat. §§ 42-110a et seq.
(“CUTPA”). Cortron removed the case to this Court and filed various counter-claims. The case
was tried to a jury, which found in favor of MacDermid and against Cortron on its counterclaims. (ECF No. 408.) The jury awarded MacDermid $35,423,997 in compensatory damages.
MacDermid Printing Solutions LLC v. Cortron Corp., 2015 WL 251527 at *21 (D. Conn. Jan.
20, 2015), aff’d in part and rev’d in part, 833 F.3d 172 (2d Cir. 2016).
Following the jury’s verdict, I denied Cortron’s motion for judgment as a matter of law
and its motion for a new trial on the condition that MacDermid agree to a remitted award of
$19,757,854 in compensatory damages. In reducing MacDermid’s compensatory damages
award of $35,423,997, I determined that the component of this award reflecting the verdict on
the CUTPA claim – $11,875,204 – “included amounts equal to the damages on the breach of
contract count ($7,903,909), and computer crimes count ($29,970), as well as a remainder equal
to one-third of the antitrust damages ($3,941,325).” Id. at *16. Because “the entirety of the
CUTPA award [was] duplicative” and “the injuries underlying [the] amounts [were]
compensated elsewhere in the verdict”, I concluded that the CUTPA award should be remitted in
its entirety, i.e., to zero. Id.
On January 22, 2015, MacDermid accepted the remittitur, “expressly accepting the

3

modified compensatory award in the amount of $19,757,854, and foregoing its right to a new
trial on damages.” (ECF No. 468 at 1.) On February 17, 2015, I entered final judgment in favor
of MacDermid in the amount of $64,670,821, representing “$19,757,854 in compensatory
damages, $27,538,889 in punitive damages, $2,641,587 in attorney’s fees, and $14,732,491 in
offer-of-compromise interest.” (ECF No. 471.) The punitive damages consisted of an amount
equal to twice the antitrust damages, plus $3,790,939 under CUTSA and $100,000 under
CUTPA. MacDermid, 2015 WL 251527 at *20.
Cortron appealed, arguing that I had erred in “(1) denying Cortron a new trial or
judgment as a matter of law on [MacDermid’s] antitrust claims; (2) permitting MacDermid to
present evidence of its lawyers’ patent advice; (3) concluding that the jury’s identical awards on
each of the antitrust claims were not duplicative; and (4) failing to remit or order a new trial on
damages regarding the antitrust and trade-secret claims.” MacDermid, 833 F.3d at 177. The
Second Circuit held that Cortron was entitled to judgment as a matter of law on MacDermid’s
antitrust claims “because MacDermid failed to present evidence that Cortron’s conduct harmed
competition,” id. at 178, but rejected the challenges to the admission of evidence regarding legal
advice and the denial of remittitur, and found it unnecessary to address Cortron’s remaining
arguments. The Second Circuit’s opinion concludes with the following paragraph:
[W]e REVERSE the judgment of the District Court insofar as it denied Cortron’s
post-verdict motion for judgment as a matter of law on MacDermid’s antitrust claims. We
otherwise AFFIRM the judgment of the District Court, leaving undisturbed the award of
damages on MacDermid’s state law claims for misappropriation of trade secrets, unfair
trade practices, computer crimes, and breach of contract. We REMAND the cause to the
District Court to recalculate damages in a manner consistent with this opinion.

Id. at 192.

4

After receipt of the mandate, on October 12, 2016, I issued an order proposing new
damages figures for a revised judgment. (ECF No. 493.) The proposed figures were the same as
those shown in the table set forth above. (See footnote 1, supra.) After MacDermid filed a
notice objecting to, and Cortron filed a notice accepting, the proposed damages calculation, I
ordered supplemental briefing. (ECF No. 496.)
III.

Discussion
The parties dispute whether the Second Circuit’s mandate requires reinstatement of the

portion of the jury’s CUTPA award I found to be duplicative of the later-reversed antitrust
award. MacDermid contends that that portion, which amounts to $3,941,325, must be included
in the revised judgment, pointing out that I remitted that portion only because I found those
damages duplicative of the antitrust award, which has now been eliminated. (ECF No. 494 at 5.)
For the reasons set forth below, I disagree.
A.

The Second Circuit’s Mandate Bars this Court from Modifying the CUTPA
Portion of the Original Judgment

Under the mandate rule, “a district court must follow the mandate issued by an appellate
court.” Puricelli v. Argentina, 797 F.3d 213, 218 (2d Cir. 2015). “Unless the court directs that a
formal mandate issue, the mandate consists of a certified copy of the [appellate court’s]
judgment, a copy of the court’s opinion, and any direction about costs.” Fed. R. App. P. 41(a);
see United States v. Reyes, 49 F.3d 63, 66 (2d Cir. 1995). The mandate “describes the duty of
the district court on remand upon receipt of the mandate.” United States v. Ben Zvi, 242 F.3d 89,
95 (2d Cir. 2001)(internal quotation marks and citation omitted). The mandate rule “compels
compliance on remand with the dictates of the superior court and forecloses relitigation of issues
expressly or impliedly decided by the appellate court.” Id. (internal quotation marks and citation
omitted)(emphasis in original). “Likewise, where an issue was ripe for review at the time of an
5

initial appeal but was nonetheless foregone, the mandate rule generally prohibits the district court
from reopening the issue on remand unless the mandate can reasonably be understood as
permitting it to do so.” Id. A district court may not consider additional issues raised by a party
after remand when the mandate has “limit[ed] the issues open for consideration on remand.”
Puricelli, 797 F.3d at 218. In construing a mandate, a district court must consider “both the
express terms and broader spirit of the mandate to ensure that its terms have been ‘scrupulously
and fully carried out.’” Id. Furthermore, “it is proper to consult the appellate opinion for
guidance in construing the mandate.” 18B Charles Alan Wright et al., Federal Practice &
Procedure § 4478.3 (2d ed. 2016).
I first consider the express terms of the mandate. The final sentence of the Second
Circuit’s judgment states that “[t]he case is REMANDED to the District Court to recalculate
damages in a manner consistent with this Court’s opinion.” (ECF No. 492 at 1.) The Court’s
opinion addresses three of the several issues Cortron raised in the appeal, and finds that “(1)
MacDermid failed to prove harm to competition” and that “[t]he District Court therefore erred in
rejecting Cortron’s Rule 50(b) motion for judgment as a matter of law on MacDermid’s antitrust
claims”; (2) “[t]he District Court did not ‘abuse its discretion’ in permitting MacDermid to
introduce evidence previously withheld under the attorney-client privilege and the work-product
doctrine”; and (3) “[t]he District Court did not ‘abuse its discretion’ in denying remittitur or a
new trial on damages on MacDermid’s state-law claim for misappropriation of trade secrets.”
MacDermid, 833 F.3d at 192. The opinion does not address MacDermid’s CUTPA claim, or the
damages awarded on that claim after my remittitur (i.e., $0 in compensatory damages and
$100,000 in punitive damages), because no party raised those issues on appeal. The mention of

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the CUTPA claim, and CUTPA damages, in the Second Circuit’s description of its judgment in
the concluding paragraph of its opinion confirms this:
[W]e REVERSE the judgment of the District Court insofar as it denied Cortron’s
post-verdict motion for judgment as a matter of law on MacDermid’s antitrust claims. We
otherwise AFFIRM the judgment of the District Court, leaving undisturbed the award of
damages on MacDermid’s state law claims for misappropriation of trade secrets, unfair
trade practices, computer crimes, and breach of contract. We REMAND the cause to the
District Court to recalculate damages in a manner consistent with this opinion.

Id. (emphasis added).
Two distinct features of the mandate make clear that I may not at this point adjust the
award of CUTPA damages, as MacDermid urges. First, the Second Circuit affirmed this Court’s
judgment in all respects except for the portion on the antitrust claims; that is thus the only
portion of the judgment I may now revisit, other than ancillary items that might be affected by
adjustments to that portion, such as interest and attorneys’ fees. (See footnote 1, supra.) Viewed
in this light, the Second Circuit’s order “to recalculate damages” means that I must remove
antitrust damages from the total award and recalculate it. This is more complicated than simply
subtracting the trebled antitrust damages (i.e., $35,471,925 (ECF No. 467 at 33)) from the total
original judgment (i.e., $64,670,821), because the original judgment also included offer-ofcompromise interest that had itself been calculated on the basis of a total damages figure that
included the antitrust award, as well as attorneys’ fees. Hence, it is necessary to “recalculate
damages” by re-starting the process of adding up the different compensatory and punitive awards
– excluding the award on the antitrust claims – and then determining any interest using the new
base.2 But there is nothing in the Second Circuit’s directive to “recalculate damages”, or in its

Note, however, that because the base of compensatory and punitive damages plus attorneys’
fees was reduced by the elimination of the antitrust award to an amount that fell below
MacDermid’s $15 million offer of compromise (i.e., $11,824,818 in compensatory and punitive
2

7

opinion, that suggests that I was to do anything more on remand than make this arithmetical
adjustment. There is certainly nothing that suggests I was to reopen a damages award on a
separate claim for unfair trade practices that the Circuit itself “le[ft] undisturbed.” MacDermid,
833 F.3d at 192. I agree with Cortron that the directive to “recalculate damages” – though
calling for more than a simple subtraction operation in this case – has a ministerial ring; it does
not suggest that I was to decide the legal question whether, had I entered judgment as a matter of
law on the antitrust claims under Rule 50(b) after the jury’s verdict, I would have had to deny
Cortron’s motion for remittitur as to the antitrust component of the CUTPA claims.3 Had the
Second Circuit intended that I decide that question on remand, it likely would have directed me
to do more than “recalculate damages in a manner consistent with” an opinion that does not
substantively address the CUTPA claim. It also likely would not have described its own
judgment as “leaving undisturbed” the CUTPA award.4

damages plus $2,641,587 in attorneys’ fees = $14,466,405), MacDermid may no longer be
entitled to offer-of-judgment interest. I raised this point in my original proposed recalculation
but have not yet rendered a final ruling on it, due to the fact that the amount of post-judgment
attorneys’ fees may affect the calculus. (ECF No. 493 at 2.)
3
Indeed, MacDermid also asks me to go further and assess a new punitive damages award under
CUTPA, after performing a full analysis of the factors endorsed by Connecticut courts for
determining punitive damages. (ECF No. 494 at 12-15.) This, too, would go well beyond
“recalculat[ing] damages.” MacDermid, 833 F.3d at 192.
4
MacDermid argues that the “leaving undisturbed” language is not part of the mandate, by
which it apparently means that that phrase does not appear in the remand order. (ECF No. 500 at
7.) But even if the Second Circuit’s judgment should be treated as “a formal mandate,” Fed. R.
App. P. 41(a), such that the mandate in this case does not include the opinion itself, I must still
consider the opinion in construing the remand order, 18B Charles Alan Wright et al., Federal
Practice & Procedure § 4478.3 (2d ed. 2016)(“[I]t is proper to consult the appellate opinion for
guidance in construing the mandate”) – especially when the remand order directs me to
recalculate damages in a manner “consistent with this Court’s opinion.” (ECF No. 492 at 1.)
8

That brings me to the second feature of the mandate rule that forecloses MacDermid’s
argument that I should restore the antitrust component5 of the original CUTPA award: Because
no party challenged the CUTPA award on appeal, “the mandate rule generally prohibits the
district court from reopening the issue on remand.” Ben Zvi, 242 F.3d at 95. The CUTPA
portion of the judgment was not challenged on appeal, was expressly “le[ft] undisturbed,” and is
thus no longer open to revision. The Second Circuit has applied this principle of finality in a
variety of contexts. See, e.g., United States v. Minicone, 994 F.2d 86 (2d Cir. 1993)(where
district court denied minor role adjustment and Second Circuit affirmed denial but remanded for
resentencing on different issue, mandate rule barred district court from granting minor role
reduction on remand). And in a case factually similar to this one, the Federal Circuit barred a
party from mounting a challenge to a punitive damages award on remand that it had not raised in
the first appeal. Tronzo v. Biomet, Inc., 236 F.3d 1342 (Fed. Cir. 2001)(district court erred in
revisiting issue of proper amount of punitive damages on remand after first appeal where
defendant did not challenge punitive damages award in first appeal).
MacDermid does not argue, and I do not find, that any “exceptional circumstances” apply
here that might warrant deviation from the mandate rule. See United States v. Webb, 98 F.3d
585, 587 (10th Cir. 1996)(“A district court may depart from an appellate court’s mandate under
exceptional circumstances, including (1) a dramatic change in controlling legal authority; (2)
significant new evidence that was not earlier obtainable through due diligence but has since
come to light; or (3) if blatant error from the prior sentencing decision would result in serious
injustice if uncorrected.” (internal quotation marks and alterations omitted)), cited in Ben Zvi,

I use the phrase “antitrust component” in this opinion only as shorthand for the portion of the
jury’s CUTPA award (i.e., $3,941,325) I found to be duplicative of the awards on the antitrust
claims.
5

9

242 F.3d at 95. Assuming the Second Circuit would adopt a “serious” or “manifest” injustice
exception to the mandate rule, I conclude that it would not apply on the facts of this case. While
it is true that CUTPA provides a broader, more flexible remedy than the antitrust laws, and one
that does not require proof of harm to competition, Cortron has shown with myriad citations to
the trial record that MacDermid repeatedly cast the portion of the CUTPA award it now seeks to
revive as derivative of its antitrust damages in arguments before the jury and before this Court.
(See ECF No. 499 at 7-10.) This is one proper – and frequent – use of CUTPA, which provides a
remedy for violations of the public policy embodied in other statutes; but when CUTPA is
employed in that derivative manner, it takes on the limits of the public policy it is advancing.
See Mead v. Burns, 199 Conn. 651, 665 (1986)(“Although Conaway holds that CUTPA may
authorize a cause of action that builds upon the public policy embodied in specific statutory
provisions, such a CUTPA claim must be consistent with the regulatory principles established by
the underlying statutes.”). Restoring the antitrust component of the CUTPA damages award
would contravene principles of antitrust law, as delineated by the Second Circuit, and thus would
be inconsistent with the statutes embodying the public policy on which the CUTPA claim was
based. In light of the way MacDermid cast its CUTPA claim here, then, there is no “serious
injustice” in declining to restore the antitrust component of the CUTPA award.6

MacDermid argues that the jury instructions do not warrant the conclusion that the jury’s
CUTPA verdict was legally derivative of its antitrust verdict, but I need not decide that issue. I
conclude only that, in light of MacDermid’s representations to the jury that its claim of a
CUTPA violation “rests on the antitrust ” issues, (ECF No. 462 at 89), it is not a “serious
injustice” to leave at zero the antitrust portion of the CUTPA award now that the Second Circuit
has found the antitrust claims legally deficient.
6

10

B. MacDermid Waived its Right to Seek Additional CUTPA Damages by Accepting
the Remittitur
The cases cited above regarding the mandate rule’s bar on reopening issues on remand
not raised in the appeal are not precisely on point here, but the way in which they differ only
further undermines MacDermid’s plea that I revisit the CUTPA award: In those cases, the party
who sought to raise the new argument on remand could have raised it in the first appeal but
chose not to do so. By contrast, MacDermid could not have appealed my remittitur of the
antitrust component of the CUTPA damages award because it accepted that remittitur rather than
opt for a new trial.7 “[A] plaintiff in federal court, whether prosecuting a state or federal cause of
action, may not appeal from a remittitur order he has accepted.” Thomas v. iStar Fin., Inc., 629
F.3d 276, 279 (2d Cir. 2010). Therefore, “[w]hen a plaintiff has agreed to a conditional
remittitur order, he is not allowed to challenge it, seeking an increase of the reduced award,
either by appealing or by filing a cross-appeal.” Rangolan v. Cty. of Nassau, 370 F.3d 239, 24344 (2d Cir. 2004)(internal citations omitted). In other words, MacDermid waived the right to
seek an adjustment to the CUTPA award before Cortron even filed the appeal.
MacDermid argues that it should be excused from the waiver on the basis of theories of
mistake or frustration of purpose, but it cites no relevant authority to support application of these
theories in this context. MacDermid also argues that failing to adjust the CUTPA award to
restore the antitrust component of the CUTPA damages would violate the Seventh Amendment,
because it would amount to eliminating what is now a non-duplicative component of the jury’s

7

As Cortron points out, however, there were steps MacDermid could have taken in the appeal to
attempt to create an opening for the argument it now seeks to make. (ECF No. 499 at 15.) For
example, it could have asked the Second Circuit, in the event of reversal on the antitrust claims,
to order that I revisit the antitrust component of the CUTPA award and decide whether it should
be reinstated. It also could have sought rehearing of the Circuit’s ruling to make the same point.
MacDermid does not suggest that it took any such steps.
11

damages award without offering MacDermid a new trial. (ECF No. 500 at 10.) But
MacDermid’s Seventh Amendment rights were already fully respected in the remittitur
procedure, Gasperini v. Center for Humanities, Inc., 518 U.S. 415, 433 (1996)(trial court has
discretion to overturn verdict for excessiveness and order new trial without qualification, “or
conditioned on the verdict winner’s refusal to agree to a reduction (remittitur)”); and it cites no
authority for the notion that it should now receive a second opportunity for a new trial because it
is dissatisfied with the effect of the Second Circuit’s ruling on its overall damages award.
Further, the Seventh Amendment does not limit the authority of a court to enter judgment as a
matter of law with respect to a claim as to which there is legally insufficient evidence – as the
Second Circuit did in this case – even if the effect of doing so is to reduce the plaintiff’s overall
damages. Id. at 436 n. 20 (Rule 50(b) motion for judgment as matter of law is “compatible with
the Seventh Amendment”); Central Office Telephone, Inc. v. AT&T Co., 108 F.3d 981, 993 (9th
Cir. 1997)(ruling on motion for judgment as matter of law that reduced plaintiff’s damages did
not require giving plaintiff option of new trial), rev’d on other grounds, AT&T Co. v. Central
Office Telephone, Inc., 524 U.S. 214 (1998).
IV.

Conclusion
For the reasons set forth above, I adopt the recalculation of compensatory and punitive

damages set forth in the table in Part I of this ruling. I previously ordered the parties to file
memoranda concerning attorney’s fees and offer-of judgment interest within fourteen days of
this order. (ECF No. 498.) I now vacate that order and issue the following order instead:
Within 21 days of today, the parties shall meet and confer with regard to attorneys’ fees
and attempt to reach agreement as to the total amount of fees the Court should include in the
revised judgment. Should the parties agree, they shall file a joint statement so indicating and

12

providing the agreed-upon amount. If no agreement is reached, each side shall file within 21
days of today, a memorandum indicating: (i) Whether fees should be allocated and, if so, in what
manner and amount, (ii) Any discovery or other proceedings necessary to effectuate such an
allocation, (iii) Whether each party agrees that offer-of-judgment interest is not currently
recoverable (i.e., based on the corrected compensatory and punitive damages and the correct
amount of attorneys’ fees), (iv) Whether and to what extent MacDermid is entitled to fees
relating to the appeal; if MacDermid seeks such fees, it shall submit proof of its appellate fees
and expenses in the same manner and format as its earlier fee submission, (ECF No. 469), (v)
Whether MacDermid should be allowed to recover fees for any further proceedings needed to
ascertain the correct amount of attorneys’ fees, and (vi) A proposed calculation of post-judgment
interest, setting forth the applicable interest rate under 28 U.S.C.§ 1961.8

IT IS SO ORDERED.

/s/
Michael P. Shea, U.S.D.J.
Dated:

Hartford, Connecticut
April 18, 2017

8

I note that both parties appear to be in agreement that post-judgment interest is recoverable, and
that such interest should be recalculated from February 17, 2015 – the date of original judgment.
(ECF No. 499 at 24); (ECF No. 494 at 17.) Therefore, the parties need not address those issues
in their memoranda.
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