In a recent letter decision, the Court of Chancery in ReCor Medical, Inc. v. Warnking, C.A. No. 7387-VCN (Del. Ch., Jan. 30, 2015), discussed the equitable considerations involved in determining whether an award of post-judgment interest should be simple or compound:

 There is no clear-cut exit from the conundrum posed by the parties. Compound interest is not a default answer because the question is committed to the Court’s discretion. Yet, on balance, the reasons cited for simple interest do not outweigh the reality that compound interest is a more accurate means of measuring the time value of money owed by Defendants to ReCor. Accordingly, interest on the fee and expense award will be compounded quarterly.