On January 22, 2016, Delaware Chancellor Andre C. Bouchard rejected a proposed “disclosure-only” settlement in In re Trulia Stockholder Litigation. The decision confirms the Chancery Court’s growing skepticism for disclosure-only settlements in merger litigation.

In In re Trulia, the Delaware Chancery Court rejected a proposed disclosure-only settlement of a shareholder suit challenging the merger between Trulia and Zillow. In declining to approve this proposed settlement, Chancellor Bouchard explained that “to the extent that litigants continue to pursue disclosure settlements, they can expect that the Court will be increasingly vigilant in scrutinizing the ‘give’ and the ‘get’ of such settlements to ensure that they are genuinely fair and reasonable to the absent class members."