Microbot Medical, Inc. v. Joseph Mona
- George Daniels
- 1:19-cv-03782
- U.S. District Court · Southern District of New York
- 4
Microbot v. Mona: Judge Daniels granted Microbot’s motion, calculating post-judgment interest from August 22, 2023, at 5.36%.
Microbot Medical, Inc. received the requested ruling on the date and rate for post-judgment interest. Joseph Mona was affected because the court applied a 5.36% interest rate beginning August 22, 2023, to the unpaid judgment balance.
What happened
Microbot Medical, Inc. sued Joseph Mona under Section 16(b) of the Securities Exchange Act, seeking repayment of profits from Mona’s securities transactions. The court had entered a $484,614.30 judgment against Mona in 2021, but later proceedings resolved Mona’s counterclaims and produced a final judgment on August 22, 2023.
Microbot asked the court to recognize satisfaction of the judgment and calculate interest on the unpaid balance from August 22, 2023, at 5.36%. Mona argued that interest should instead run from March 31, 2021, at 0.07%.
Judge Daniels adopted the magistrate judge’s report and granted Microbot’s motion. The court ruled that August 22, 2023, was the relevant date because it was the date of the final enforceable judgment, and directed the Clerk to close the case and the pending motion.
The detailed version
- Microbot Medical, Inc. v. Joseph Mona · No. 1:19-cv-03782
- George Daniels
- Sept. 17, 2025
Background
Microbot Medical, Inc. brought this action against Joseph Mona under Section 16(b) of the Securities Exchange Act of 1934, alleging that Mona failed to return profits from his purchase and sale of securities. Mona later asserted counterclaims under Section 10(b) of the Act and Securities and Exchange Commission Rule 10b-5.
On March 31, 2021, the court entered a $484,614.30 judgment against Mona on Microbot’s Section 16(b) claim. The court later granted Mona’s request to stop enforcement of that judgment while his counterclaims were pending. On August 22, 2023, the court granted Microbot summary judgment and dismissed Mona’s counterclaim with prejudice, and the Clerk entered a final judgment that day.
In August 2025, Microbot moved for entry of partial satisfaction of judgment for the full $484,614.30 balance. It argued that post-judgment interest on the unpaid balance should be calculated from August 22, 2023, at 5.36%. Mona opposed the motion, arguing that interest should be calculated from March 31, 2021, at 0.07%.
Report and Recommendation
Magistrate Judge Robert W. Lehrburger recommended granting Microbot’s motion. Neither party objected. Judge Daniels therefore reviewed the report for clear error, meaning an obvious mistake after reviewing the record.
Court’s Analysis
Federal law provides that post-judgment interest in civil cases begins on the date judgment is entered and uses the applicable Treasury-yield rate. The court explained that this interest compensates a plaintiff for the delay between reducing damages to an enforceable judgment and the defendant’s payment.
The court concluded that August 22, 2023, was the proper date for calculating interest. Although Mona argued for the March 31, 2021 judgment date, the court noted that Mona had successfully obtained an order quashing execution of the 2021 judgment, which made that judgment unenforceable. The August 22, 2023 judgment was the final and enforceable judgment, so the court approved the 5.36% interest rate associated with that date.
Disposition
Judge Daniels adopted Magistrate Judge Lehrburger’s report and granted Microbot’s motion for entry of partial satisfaction of judgment. The Clerk of Court was directed to close the case and the pending motion at ECF No. 301.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.