Innovative Solutions International Inc v. Houlihan Trading Co Inc

1 THE HONORABLE JOHN C. COUGHENOUR [5] UNITED STATES DISTRICT COURT [6] WESTERN DISTRICT OF WASHINGTON 7 AT SEATTLE 8 INNOVATIVE SOLUTIONS CASE NO. C22-0296-JCC INTERNATIONAL, INC., [9] Plaintiff, ORDER [10] v. [11] HOULIHAN TRADING CO., INC, et al., [12] Defendants. [13] 14 This matter comes before the Court on Defendant Houlihan Trading Company, Inc.’s 15 (hereinafter “Houlihan”) motion for reconsideration (Dkt. No. 390). Specifically, Houlihan asks 16 the Court to reconsider or clarify its supplemental judgment (Dkt. No. 389), which did not 17 reference post-judgment interest for Houlihan’s original jury award of $1.5 million, (Dkt. No. 18 348 at 2). (See generally Dkt. No. 390.) 19 Motions for reconsideration are generally disfavored. LCR 7(h)(1). They are only 20 appropriate where there is “manifest error in the prior ruling or a showing of new facts or legal 21 authority which could not have been brought to [the Court’s] attention earlier with reasonable 22 diligence.” Id. “Manifest error” is “an error that is plain and indisputable, and that amounts to a 23 complete disregard of the controlling law or the credible evidence in the record.” Munoz v. 24 Locke, 2013 WL 12177035 , slip op. at 2 (W.D. Wash. 2013) (internal citation and quotation 25 omitted). In turn, a motion for reconsideration is improper if it merely asks the Court to “rethink 26 what it had already thought through—rightly or wrongly.” Wilcox v. Hamilton Constr., LLC, 426 1 F. Supp. 3d 788, 791 (W.D. Wash. 2019) (cleaned up); see, e.g., Brown v. Murphy, 2023 WL 2 6481566, slip op. at 1 (W.D. Wash. 2023); Hoffman v. Transworld Sys. Inc., 2019 WL 109437 , 3 slip op. at 1 (W.D. Wash. 2019). 4 Houlihan contends that the Court committed manifest error in failing to “apply post5 judgment interest to the original judgment of $1.5 million.” (Dkt. No. 390 at 4.) The Court 6 agrees that it neglected to mention the original $1.5 million jury award in the post-judgment 7 interest section of its supplemental judgment. (See Dkt. No. 389 at 1–2.) But this was no more 8 than a clerical oversight; it certainly does not rise to the level of manifest error. Accordingly, the 9 Court DENIES Houlihan’s motion for reconsideration (Dkt. No. 390). However, pursuant to 10 Rule 60(a), the Court will enter an amended supplemental judgment to correct the clerical error. 11 Fed. R. Civ. P. 60(a). [13] 14 DATED this 8th day of May 2025. A [17] John C. Coughenour [18] UNITED STATES DISTRICT JUDGE