William J. Brown v. Matterport, Inc.
CourtCourt of Chancery of Delaware
Date FiledJune 1, 2026
Docket2021-0595-LWW
StatusPublished
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Full Opinion
COURT OF CHANCERY
OF THE
STATE OF DELAWARE
LORI W. WILL LEONARD L. WILLIAMS JUSTICE CENTER
VICE CHANCELLOR 500 N. KING STREET, SUITE 11400
WILMINGTON, DELAWARE 19801-3734
June 1, 2026
Joseph L. Christensen, Esquire Robert L. Burns, Esquire
Christensen Law LLC Kyle H. Lachmund, Esquire
1201 North Market Street, Suite 1404 Nicole M. Henry, Esquire
Wilmington, Delaware 19801 Brendan W. Clark, Esquire
Richards, Layton & Finger, P.A.
920 North King Street
Wilmington, Delaware 19801
RE: William J. Brown v. Matterport, Inc., et al.,
C.A. No. 2021-0595-LWW
Dear Counsel:
This letter opinion addresses the outstanding issue remanded by the Delaware
Supreme Court concerning the calculation of post-judgment interest.
On April 22, 2025, the Supreme Court affirmed this court’s post-trial decision
in all other respects but remanded for the limited purpose of recalculating post-
judgment interest tied to the July 1, 2024 Order and Final Judgment.1 To harmonize
the awards of prejudgment and post-judgment interest, prejudgment interest on the
damages award accrued at the affirmed rate of 5.25%, compounded quarterly,
1
Matterport, Inc. v. Brown, 340 A.3d 1149, 2025 WL 1166116 (Del. 2025) (ORDER).
C.A. No. 2021-0595-LWW
June 1, 2026
Page 2 of 4
through July 1, 2024.2 The Supreme Court explained that this court remains “free
to exercise its discretion as to the rate of interest and whether and to what extent
post-judgment interest is to be compounded.”3
Plaintiff William Brown argues that 6 Del. C. § 2301 mandates a fixed 10.50%
rate based on the Federal Discount Rate in effect on July 1, 2024. 4 The defendants
respond that the court should maintain the 5.25% rate used for prejudgment interest
to avoid a windfall to Brown.5
In the Court of Chancery, the statutory legal rate serves as a benchmark, not
an inflexible rule.6 Exercising my equitable discretion, I conclude that neither a
fixed 10.50% rate nor a fixed 5.25% rate is appropriate here. A fixed 10.50% rate
would create an inequitable windfall for Brown and effectively operate as a sanction
for conduct I previously held stemmed from a good-faith misunderstanding.7
Conversely, permitting the defendants to retain the judgment amount in a high-
2
Id. at *1-2 (reversing the “chosen end date” for prejudgment interest to “harmonize” the
awards, but affirming the award of prejudgment interest “on the basis of and for the reasons
stated in the Memorandum Opinion”).
3
Id. at *2.
4
See Pl.’s Mot. to Enter J. Consistent with Supreme Ct.’s Order (Dkt. 343) ¶ 20.
5
See Defs.’ Opp’n to Pl.’s Mot. to Enter J. Consistent with Supreme Ct.’s Order (Dkt. 347)
(“Defs.’ Opp’n”) ¶¶ 4-5.
6
See Energy Transfer, LP v. Williams Cos., 346 A.3d 1089, 1120 (Del. 2023) (explaining
that “the legal rate is a mere guide” (citation omitted)).
7
See Brown v. Matterport, Inc., 2024 WL 2745822, at *12 (Del. Ch. May 28, 2024).
C.A. No. 2021-0595-LWW
June 1, 2026
Page 3 of 4
interest environment at a fixed 5.25% rate would not fully compensate Brown for
the loss of the use of his funds. It would instead effectively subsidize the defendants’
continued retention of those funds.
Applying a floating rate compounded quarterly appropriately accounts for the
economic realities and significant fluctuations in interest rates during the relevant
period.8 To reflect these dynamics, post-judgment interest will accrue at a floating
rate equal to 5% over the Federal Reserve discount rate, fluctuating therewith,
compounded quarterly.
Separately, Brown argues in his reply that, if a floating rate is adopted for
post-judgment interest, “equity requires” the same for prejudgment interest. 9
Because the Supreme Court affirmed the award of prejudgment interest, I cannot
alter the 5.25% rate on remand. 10
8
See Fortis Advisors LLC v. Johnson & Johnson, 2024 WL 4048060, at *54 (Del. Ch.
Sep. 4, 2024) (noting that a variable rate “accounts for the economic realities during the
relevant period, which saw significant swings in interest rates”), aff’d in part, rev’d in part
on other grounds sub nom. Johnson & Johnson v. Fortis Advisors LLC, 352 A.3d 229 (Del.
2026); see also Murphy Marine Servs. of Del., Inc. v. GT USA Wilm., LLC,
2022 WL 4296495, at *24 (Del. Ch. Sep. 19, 2022) (explaining that compounding interest
“reflects the financial realities of conducting business”).
9
See Pl.’s Reply in Supp. of Mot. to Enter J. Consistent with Supreme Ct.’s Order
(Dkt. 350) 10 n.1.
10
See Cede & Co. v. Technicolor, Inc., 884 A.2d 26, 38 (Del. 2005) (explaining that “when
an appellate court remands for further proceedings, the trial court must proceed in
accordance with the appellate court’s mandate as well as the law of the case established on
appeal”).
C.A. No. 2021-0595-LWW
June 1, 2026
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Finally, the defendants’ request to terminate the accrual of post-judgment
interest as of June 1, 2025 is denied.11 The defendants could have tolled the accrual
of interest at any point after the Supreme Court issued its mandate by satisfying the
judgment. They chose not to do so. To fully compensate Brown, interest will
continue to accrue until the judgment is paid in full.
The parties are directed to confer on a date certain for the payment of the
judgment and to file a proposed final order containing an interest calculation
consistent with this decision. That proposed order must be filed within 20 days.
IT IS SO ORDERED.
Sincerely yours,
/s/ Lori W. Will
Lori W. Will
Vice Chancellor
11
Defs.’ Opp’n ¶¶ 26-27.