I really wanted to order my E92 with manual seats. First, the manual seats in our E90 are very nicely adjustible. Second, the electric seats way a freaking ton. Third, I'm probably keeping this long term, and it's just something else to break. Fourth, the electric seats way a freaking ton.
But ultimately I went with the electric because I read a few too many posts by manual seat M3 owners complaining they couldn't adjust the seat as precisely as they wanted.