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Appeals DE Supreme Court

Dechert LLP

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

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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

Dechert LLP

Dechert Re:Torts - Issue 9

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Delaware Supreme Court Rejects No-Injury Medical Monitoring Claims - As part of our ongoing coverage of issues in Medical Monitoring, we noted that the Delaware Supreme Court received a certified question from the U.S....more

White and Williams LLP

Insurer Doomed in Delaware by the Sutton Rule

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In Donegal Mut. Ins. Co. v. Thangavel, No. 379, 2022, 2023 Del. LEXIS 227, the Supreme Court of Delaware (Supreme Court) considered whether the Sutton Rule prevented the plaintiff from pursuing subrogation against the...more

Maron Marvel

Delaware Supreme Court to Decide Whether Increased Risk of Illness Constitutes a Claim in Delaware

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The Delaware Supreme Court heard arguments on June 14, 2023, on a question certified to it from the Third Circuit of the U.S. Court of Appeals, as to whether medical monitoring claims can be made in Delaware without proof of...more

Maron Marvel

Delaware Supreme Court Considers Responsibility for PCBs In the Environment

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The Delaware Supreme Court heard arguments in late March in a lawsuit on appeal by the State of Delaware seeking to hold Monsanto as a manufacturer responsible for polychlorinated biphenyls (PCBs) that have contaminated...more

Proskauer Rose LLP

Del. Bankruptcy Rulings Instruct on Creditors' Rights to Sue

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Creditors of distressed businesses are often frustrated by shareholder- controlled boards when directors pursue strategies that appear to be designed to benefit shareholders at the creditors' expense. In these...more

Sheppard Mullin Richter & Hampton LLP

California Court of Appeal Addresses Derivative Standing and Failure of Oversight Claims Under Delaware Law

In Tola v. Bryant, No. 16150, 2022 Cal. App. LEXIS 241 (Cal. App. Mar. 24, 2022), the First Appellate District of the California Court of Appeal applied Delaware’s new formulation of the test for determining whether a...more

Mintz Edge

Delaware Supreme Court Upholds Advance Waiver Of Statutory Appraisal Rights

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The Delaware Supreme Court recently decided that an agreement (sometimes referred to as a “drag along”) to waive prospectively statutory appraisal rights is fully enforceable against the common stockholders who made such...more

Fenwick & West LLP

Delaware Supreme Court Endorses a New Three-Part Demand Futility Test

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On September 23, 2021—in United Food and Commercial Workers v. Zuckerberg—the Delaware Supreme Court endorsed a new universal three-part demand futility test. The decision will likely have far-reaching consequences, including...more

Fenwick & West LLP

Delaware Supreme Court Holds That Dilution Claims Against a Controller Are Solely Derivative, Overruling Prior Precedent

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On September 20, 2021, the Delaware Supreme Court took the highly unusual step of overruling its prior decision in Gentile v. Rossette. An oft-criticized precedent from 2006, Gentile created an exception allowing minority...more

Goodwin

SCOTUS Grants Certiorari to Decide Whether Automatic Discovery Stay Applies to Securities Act Cases in State Court

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SCOTUS Grants Certiorari to Decide Whether Automatic Discovery Stay Applies to Securities Act Cases in State Court; Delaware Court of Chancery Dismisses Stockholder Suit Against FedEx for Failure to Make Pre-Litigation...more

McDermott Will & Emery

Board Motives Matter: Delaware Supreme Court Remands Dilutive Stock Sale Case

The following case (link) should serve as a cautionary tale for directors of Delaware corporations when taking actions that may disenfranchise stockholders, especially in the election of directors. The Delaware Supreme...more

Pillsbury Winthrop Shaw Pittman LLP

The Need to Be Deliberate about Fraud Carve-Outs

Express Scripts: Delaware Supreme Court holds that an otherwise undefined “deliberate fraud” carve-out to an indemnification provision is limited to intentional fraud and does not include recklessness. Specific provisions...more

Goodwin

New York Federal Court Dismisses Securities Fraud Claims Against Alkermes For Lack Of Fraudulent Intent

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New York Federal Court Dismisses Securities Fraud Claims Against Alkermes for Lack of Fraudulent Intent; Fourth Circuit Affirms District Court’s Denial of Leave to File Amended Complaint Against Triangle Capital as Futile;...more

Troutman Pepper

Fiduciary Duty Of Disclosure Does Not Apply To Individual Transactions With Equityholders

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In Dohmen v. Goodman, the Delaware Supreme Court declined to impose an affirmative fiduciary duty of disclosure on a general partner arising out of the general partner’s solicitation of capital contributions from a limited...more

Morgan Lewis

Delaware Supreme Court Ruling Allows Exclusive Federal Forum Provisions For ’33 Act Claims

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The Delaware Supreme Court held on March 18 in Salzberg, et al. v. Sciabacucchi that the exclusive federal-forum provisions in certificates of incorporation for three Delaware corporations were not facially invalid....more

Bass, Berry & Sims PLC

Advance Notice Bylaw Provisions Upheld by Delaware Supreme Court

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In a previous blog post, we discussed the Delaware Chancery Court’s decision in Saba Capital Master Fund, Ltd. v. Blackrock Credit Allocation Income Trust and its relevance to the interpretation of advance notice bylaw...more

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden's 2020 Insights

Despite political and economic uncertainties, markets and deal activity were resilient in 2019, and strong fundamentals remain in place heading into 2020. Companies continue to face a challenging litigation and enforcement...more

Skadden, Arps, Slate, Meagher & Flom LLP

Recent Trends in Books and Records Litigation

Recently, the frequency of stockholder demands to inspect corporate books and records pursuant to Section 220 of the Delaware General Corporation Law has increased. In turn, the case law concerning Section 220 demands is...more

Carlton Fields

Is Your “Securities Claim” Actually Covered Under Your D&O Policy? A Review of In Re Verizon Insurance Coverage Appeals

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The question of what constitutes a “securities claim” in the context of public company D&O policies is often debated in insurance coverage disputes, and the answer to this question can have significant effects on the scope of...more

Foley & Lardner LLP

INSIGHT: New Corporate Board Procedures Advisable to Satisfy Duty of Oversight

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In Marchand v. Barnhill, a unanimous Delaware Supreme Court imposed substantial new procedural expectations on corporate directors to satisfy their fiduciary duty of oversight related to material risk areas and legal...more

White & Case LLP

Defying gravity: US M&A H1 2019: Three key M&A decisions from Delaware courts

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The first half of 2019 saw several decisions from the Delaware courts that will affect M&A dealmaking - Aruba: Supreme Court awards "deal price less synergies" in closely watched appraisal case - Rejecting the Chancery...more

Morris James LLP

Delaware Supreme Court Highlights Risks Involved in Court Rules Governing Confidential Filings

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DowDuPont Inc. v. The Chemours Co., C.A. No. 2019-0351 (Del. June 26, 2019). A recent Delaware Supreme Court Order emphasizes the risks associated with the presumptions of public access to court filings and the...more

Dechert LLP

Delaware Supreme Court Reverses Dismissal of Caremark Claim, Finding Lack of Board-Level Oversight and Director Independence

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In Marchand v. Barnhill et al. (“Blue Bell”),1 the Delaware Supreme Court on June 19 unanimously reversed the dismissal of a shareholder derivative lawsuit against the members of the board of directors and two officers of...more

A&O Shearman

Delaware Supreme Court Affirms Judgment In Favor Of Defendant On The Basis Of Plaintiffs' Failure To Prove Damages

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On May 16, 2019, the Supreme Court of Delaware affirmed a judgment by Vice Chancellor J. Travis Laster of the Delaware Court of Chancery in favor of Potomac Capital Partners II, LP on claims by shareholder plaintiffs that the...more

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