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Post-Election Regulatory Changes to Corporate Governance Mirror Broader Political Shift

Significant post-election shifts in corporate governance policy are already occurring among regulators, self-regulatory organizations and proxy advisors. The SEC will no longer litigate its climate disclosure rules,...more

No Toll for Corporations Leaving Delaware on a Clear Day

Delaware Supreme Court holds business judgment rule applies to decision to reincorporate a company out of Delaware made on a “clear day.” For a non-ratable benefit to give rise to a conflict and trigger entire fairness,...more

Delaware Supreme Court Reaffirms High Bar for Proving Control by a Minority Stockholder

Delaware Supreme Court reaffirms that “the test for actual control by a minority stockholder is not an easy one to satisfy.” Supreme Court makes clear that control by a minority stockholder is “not presumed.” Supreme Court’s...more

Securities and Derivative Litigation: Quarterly Update - November 2024

Highlight the steady pace of filings for artificial intelligence-related securities class actions; Analyze an opinion by the Eastern District of Michigan denying class certification and illustrating how courts are...more

Delaware Court of Chancery Rules No Supermajority for Nevada Reincorporation

Court of Chancery rejects claim that certificate of incorporation of a Delaware corporation requires supermajority vote for conversion to a Nevada corporation. Court holds that certificate provision requiring...more

Delaware Court of Chancery Emphasizes the High Burden of Pleading Oversight Claim

Court of Chancery rejects Plaintiffs’ claims that directors engaged in “affirmative lawbreaking for profit”, finding alleged “trifling or technical” violations are ones “over which reasonable minds can differ.” Court...more

Delaware Governor Signs Controversial “Market-Practice” Amendments to General Corporation Law

Amendments were adopted to restore market practices impacted by three recent Court of Chancery decisions. Amendments simplify the approval of a merger by a board of directors, thereby removing the potential for certain...more

PE Firm with Minority Interest Defeats Antitrust Claim—But FTC Scrutiny of Roll-Ups Likely to Continue

District court finds minority investors in companies accused of antitrust violations are not liable solely by virtue of holding a minority ownership stake. To obtain injunctive relief, the FTC must allege specific facts...more

After Delaware Court of Chancery Subjects Reincorporation Decision to Entire Fairness, Delaware Supreme Court Says Not so Fast

The Delaware Court of Chancery issued an order in Palkon v. Maffei on February 20, 2024, holding that a decision by the boards of directors and the controller of TripAdvisor, Inc. (“TripAdvisor”) and Liberty TripAdvisor...more

In Long-Awaited Match Decision, Delaware Supreme Court Expands MFW Requirements in Conflicted Controller Transactions

Delaware Supreme Court rejects attempt to limit MFW to controller buyout transactions. Supreme Court instead holds that all of MFW’s requirements for shifting the standard of review from entire fairness to business...more

Delaware Court of Chancery’s Rescission of Elon Musk’s US$55.8 Billion Pay Package Signals Expansion of Scrutiny into Potential...

The Delaware Court of Chancery issued a post-trial opinion, on January 30, 2024, in Tornetta v. Musk, holding that Tesla’s board of directors (the “Board”) breached its fiduciary duties in awarding CEO Elon Musk (with the...more

Business Coalition Sues California to Block New Climate Disclosure Laws

On January 30, 2024, the U.S. Chamber of Commerce and five co-plaintiffs representing a coalition of business groups filed a lawsuit against the California Air Resources Board (“CARB”), an agency of the State of California...more

Delaware Court of Chancery Identifies Fiduciary Duties and Standard of Review for Controlling Stockholder

In a landmark decision, In re Sears Hometown & Outlet Stores, Inc. Stockholder Litigation,1 the Delaware Court of Chancery held that a controlling stockholder did not breach his fiduciary duties when he amended company bylaws...more

Hsu Untied interview with Rick Horvath, Partner at Dechert [Video]

An interview with Rick Horvath, Partner at Dechert by Richard Hsu...more

Caremark Claim Based on Business Risks Dismissed

The Court of Chancery continues its consideration of whether a director or officer’s oversight duties, set forth in the seminal case of In re Caremark International Inc. Derivative Litigation and its progeny, apply to...more

Delaware Books and Records Demands in 2023: Protections and Pitfalls for Companies

The past year saw significant developments in the Delaware courts for books and records inspection demands pursuant to Section 220. In a first-of-its-kind decision, the Court rejected an inspection demand as lacking a...more

California Governor Signs Climate Disclosure Bills with Significant Impact for Entities of All Forms Doing Business in the State

The two new California laws apply to both public and private corporations, partnerships, limited liability companies, or other business entities meeting applicable revenue thresholds and doing business in California, without...more

Delaware Court of Chancery Awards Upwards of US$400 Million in Damages for Aiding and Abetting Claim Against Acquiror

The Delaware Court of Chancery penned the latest chapter, on June 30, 2023, in a long-running dispute concerning TC Energy Corporation’s (“TransCanada”) July 2016 acquisition of Columbia Pipeline Group (“Columbia”), holding...more

Securities and Derivative Litigation: Quarterly Update - July 2023

Examine a major Ninth Circuit decision affirming dismissal of a Section 14(a) derivative action based on a forum-selection clause; Highlight the Third Circuit’s adoption of the Omnicare standard for securities fraud claims;...more

Delaware Court of Chancery Cuts “Merger Taxes” by Holding Supplemental Disclosures Must Be Material to Warrant a Mootness Fee

Chancellor McCormick of the Delaware Court of Chancery issued an Opinion on July 6, 2023, in Anderson v. Magellan Health, Inc., imposing a new, heightened standard of review of requests for mootness fees predicated on...more

Delaware Court of Chancery Bars Stockholder from Inspecting Books and Records Related to Board’s ESG-Related Decision

Proof that an inspection demand is improperly “lawyer-driven” will overcome a stockholder’s pretextual claim for investigating wrongdoing. A stockholder does not have a proper purpose for investigating an “ordinary...more

The Developing Litigation Risks from the ESG Backlash in the United States

In the past year, environmental, social, and governance (“ESG”) practices have faced heightened scrutiny in the United States from state attorneys general, state and federal legislators, other government officials, and...more

Delaware Supreme Court Affirms Tesla’s Acquisition of SolarCity as “Entirely Fair”

The Delaware Supreme Court affirms the Court of Chancery’s determination that Tesla’s acquisition of SolarCity was the result of fair dealing, reflected a fair price, and was entirely fair—even when the process was...more

Supreme Court Gives Securities Plaintiffs No Slack: Section 11 Requires Tracing Shares to Registration Statement

U.S. Supreme Court resolves circuit split created by Ninth Circuit decision which had held that traceability not required in the context of a direct listing. By requiring traceability, the Supreme Court cabins strict...more

Delaware Court of Chancery Finds for Oracle Founder Larry Ellison and CEO Safra Catz in Post-Trial Decision Arising from Oracle’s...

Court of Chancery holds that conflicted transactions involving a potential controller may still be considered under the deferential business judgment rule, rather than entire fairness, if the evidence does not establish the...more

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