BlockFi Inc., 22-19361

John Van Tubergen filed a $10 million claim against BlockFi, Inc. in its Chapter 11 bankruptcy case, related to prepetition loan agreements (LSAs).
The bankruptcy court previously reduced Van Tubergen’s claim to $19.07, finding BlockFi’s collateral liquidation and calculation method were contractually permitted.
Van Tubergen moved for reconsideration, arguing the court made errors in its legal and factual analysis.
The LSAs gave BlockFi discretion to determine the collateral valuation method for loan-to-value (LTV) calculations and established notice requirements for collateral liquidation.
BlockFi used its chosen (lowest price point) valuation methodology for liquidating Van Tubergen’s digital asset collateral after applicable LTV ratios were breached.
Judge Michael B. Kaplan presided and considered arguments and evidence presented both initially and on reconsideration.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proper LTV Calculation Method	BlockFi used improper/unreasonable LTV method	Method was within LSA discretion	BlockFi’s method reasonable; no error
Applicability of Michigan Law	Court failed to apply Michigan contract law	Not relevant; LSAs control	No violation under Michigan law
Sufficiency of Liquidation Notice	BlockFi did not provide required 72-hour notice	Notice was provided via emails	Sufficient notice was provided
Wrongful Liquidation of Specific Loan	BlockFi admitted wrongful liquidation of one loan	No such admission/breach	No breach or admission by BlockFi found

In re Energy Future Holdings Corp., 904 F.3d 298 (3d Cir. 2018) (lists standards for reconsideration under Rule 59(e))
North River Ins. Co. v. CIGNA Reins. Co., 52 F.3d 1194 (3d Cir. 1995) (standard for granting motions to reconsider)
Lon v. E.I. Du Pont de Nemours & Co., 935 F.2d 604 (3d Cir. 1991) (motions for reconsideration are granted sparingly)
In re Christie, 222 B.R. 64 (Bankr. D.N.J. 1998) (motions for reconsideration not for re-arguing previously decided issues)