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Is Failing To Hold A Formal Board Meeting A Breach of Contract?

In yesterday's post, I discussed Tuli v. Specialty Surgical Center of Thousand Oaks, LLC, 2024 WL 4499271 (Oct. 16, 2024) and whether alleged personal animosity vitiated application of the business judgment rule to the...more

Where Corporations Most Often Propose To Reincorporate

Recently, I wrote that The Trade Desk, Inc. is proposing to reincorporate from Delaware into Nevada.  An appendix to the company's definitive proxy statement includes a table of Proposed Reincorporations, Proxy Filings from...more

Yet Another Corporation Proposes Move From Delaware To Nevada

Regular readers of this blog will know that Nevada corporate law has been a long-time interest for me.  That interest began several decades ago when I wrote the first treatise on Nevada corporate law.  That treatise was...more

Corporation Proposes Fixes To Defective Amendments Increasing The Authorized Number Of Shares And Changing Name

In 2020, GlobalTech Corporation, a Nevada corporation, filed an amendment to its articles of incorporation increasing its authorized number of shares of common stock from 10 million to 500 million.   The amendment was...more

Has Professor Solomon Rebutted Vice Chancellor's Theory Of Damages In Palkon v. Maffei?

Palkon v. Maffei, 311 A.3d 255 (Del. Ch. 2024), cert. denied, No. 2023-0449-JTL, 2024 WL 1211688 (Del. Ch. Mar. 21, 2024) involved a challenge to the proposed reincorporation of TripAdvisor, Inc. from Delaware to Nevada. ...more

Another Delaware Publicly Traded Company Proposes A Nevada Move

Last week, Chromocell Therapeutics Corporation filed preliminary proxy materials that included a proposal to reincorporate in Nevada.  Rather than convert, the company is proposing to effect the reincorporation by means of a...more

When Two Corporate Laws Diverge, Does Choosing One Make All The Difference?

In a new article, professor of law Wendy Gerwick Couture aims for "a fuller understanding of Nevada corporate law, both substantively and theoretically, as compared with Delaware corporate law".  For the title and them of her...more

Is A Change In Transfer Restrictions In A Shareholder Agreement Subject To Qualification?

A recent post discussed whether amending a shareholders agreement is subject to qualification under the California Corporate Securities Law of 1968.  For the purpose of that discussion, it is important to recognize that not...more

Cave Delaware Aut Bene Dormi Delaware?

I began writing about Nevada Corporate Law more than three decades ago with an article entitled "The Nevada Corporation: Is It A Good Bet?".  14 CEB California Business Law Reporter 259 (1992).  In the ensuing decades, I have...more

California Decides That The Sun Shall Not Set On Virtual Meeting Statutes

Despite being home to the Silicon Valley, California has not embraced with abandon virtual-only meetings of shareholders.  Section 600(e) of the Corporations Code currently does not permit virtual only meetings unless one of...more

Do Nevada Courts Ignore Delaware Precedents?

In a recently released article, Professor Stephen Bainbridge tackles the question of just how real the DExit phenomenon might really be.  Among other things, he responds to my argument that Nevada eschews Delaware law...more

DExit - Would Oliver Cromwell Reincorporate In Nevada?

Yesterday's post highlighted Professor Stephen Bainbridge's recently posted article, DExit Drivers: Is Delaware's Dominance Threatened?  His article analyzes the reasons that companies give for leaving Delaware for other...more

Another Publicly Traded Delaware Corporation Propose Move To Nevada

I recently came across another publicly traded Delaware corporation with plans to reincorporate in Nevada.  Interestingly, this corporation, Sonoma Pharmaceuticals, Inc., originally began as a California corporation and then...more

Directors Removing Directors

Seven years ago, I addressed the question of whether the board of directors of a California corporation could remove a fellow director...more

The SEC Continues Its War On Crime Victims

More than a decade ago, I expressed concern when the Securities and Exchange Commission charged Koss Corporation and one its CEO, Mr. Koss, with filing materially false financial statements after the corporation had...more

No Exit: Stockholders Fail To Grant Leave To Leave Delaware For Nevada

In news that should cheer hearts in Delaware, the stockholders of Fidelity National Financial, Inc. last week failed to approve a proposal to convert the corporation from a Delaware to a Nevada corporation.  I characterize...more

Home Means Nevada For This Corporation, But Its Heart Remains Exclusively With The Delaware Court Of Chancery

In 2019, the Nevada legislature added a provision to the state's corporate law permitting the articles of incorporation or bylaws to require, to the extent not inconsistent with any applicable jurisdictional requirements and...more

When Must A Proxy Include The "General Nature Of The Matter To Be Voted On"?

The California Nonprofit Corporation Law defines a "proxy" as a "written authorization signed by a member or the member's attorney in fact giving another person or persons power to vote on behalf of such member".  Cal. Corp....more

How The Mandatory Indemnification Statutes Of Nevada And Delaware Differ

Both Delaware and Nevada require corporations to indemnify certain persons against expenses (including attorneys' fees) to the extent that they have been successful on the merits or otherwise in defense of any action, suit or...more

Converting A Corporation Is Not Domestication

In a recent post, I took note of another Delaware corporation that had disclosed plans to convert to a Nevada corporation.  The Form 8-K filed by this company included the following statement...more

Another Public Company Announces Plan To Decamp To Nevada - Is Delaware's Dam About To Burst?

The Delaware dam may not be bursting but there are signs that it is leaking.  In an earlier post, I observed that despite all of the talk, I had not found many recent examples of publicly traded companies reincorporating in...more

Strangers In A Strange Land - In California, Bumblebees, Crabs and Snails Are Fishes And A General Partnership May Soon Be A...

In California, some things are not what they seem.  Here, a bumblebee, a crab or snail can be a fish, but a goldfish may not be a fish. Now, a bill is pending in the California legislature which threatens even more violence...more

Boilerplate Risk Factors - Is Nicolai Ivanovich Lobachevsky To Blame?

A recent paper by four law professors takes a look at risk factor disclosures in Form 10-Qs and 10-Ks filed by 3,000 firms from January 2020 through the end of 2023.  Stephen Choi, Mitu Gulati, Xuan Liu, and Adam...more

California Legislator Proposes To Enhance Criminal Fines For California, But Not Delaware, Business Entities

In February of this year, California Assembly Member Jesse Gabriel introduced a bill making certain technical, nonsubstantive changes to a provision of the Penal Code concerning the removal of prison inmates for court...more

Are Delaware Corporations "Rolling Down Hill, Like A Snowball Headed For . . ."?

For Delaware, are the good times really over for good?  University of Virginia School of Law Professor Michal Barzuza fears that they might in a recently posted a draft of her upcoming article entitled "Nevada v....more

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