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Commercially Reasonable Efforts

Jones Day

Earnouts in M&A Transactions: Recent Decisions From Delaware

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In 2024, Delaware courts issued multiple instructive decisions on earnout provisions in life sciences M&A transactions. ...more

Fenwick & West LLP

Navigating and Litigating 'Commercially Reasonable Efforts' Provisions: Considerations and Strategies for Tech & Life Sciences...

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Commercially reasonable efforts (CRE) provisions are a common feature in technology and life sciences agreements, particularly in development collaborations, licensing deals, and milestone-based contracts. ...more

Troutman Pepper Locke

Chancery Addresses "Commercially Reasonable Efforts" Clauses in the Context of an Earnout Dispute

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In Shareholder Representative Services LLC v. Alexion Pharmaceuticals, Inc., the Delaware Court of Chancery addressed an earnout dispute, holding that a buyer violated its contract with the seller by failing to use...more

Mayer Brown

Delaware Law Alert: Efforts Standards in Life-Sciences Earnout Provisions

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In two significant recent opinions, the Delaware Chancery Court ruled against the buyers of life sciences companies, holding that they failed to apply commercially reasonable efforts to achieve earnout milestones. In Fortis...more

Vinson & Elkins LLP

Series of Delaware Court of Chancery Decisions Highlights Importance of Earnout Drafting

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In recent months, the Delaware Court of Chancery has decided four significant cases regarding merger agreement earnout provisions. Most notably, in one of the largest judgments ever awarded by the Court, it found Johnson &...more

Goodwin

Life Sciences Licensing and M&A Update: Catching Up on Recent Decisions Affecting Commercially Reasonable Efforts Definitions and...

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Recently, the Delaware Chancery Court and the Third Circuit issued three significant decisions on key issues affecting licensing and M&A transactions in the life sciences industry....more

Cadwalader, Wickersham & Taft LLP

Delaware Court of Chancery Clarifies “Commercially Reasonable Efforts” in Earn-Out Provisions

On April 30, 2024, in Himawan, et al. v. Cephalon, Inc., et al., the Delaware Court of Chancery held that the defendant acquiror complied with its contractual obligations to use commercially reasonable efforts to achieve...more

Morrison & Foerster LLP

UCC Foreclosure Commercially Reasonable

In a recent case, U.S. District Judge Edgardo Ramos ruled that a foreclosure sale governed by Article 9 of the New York Uniform Commercial Code (UCC) was “commercially reasonable” when viewed as a whole, denying claims made...more

Lathrop GPM

Seventh Circuit Affirms Dismissal of Inventor’s Claim that Distributor Failed to Use Commercially Reasonable Efforts to Sell Its...

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The Seventh Circuit Court of Appeals affirmed an Indiana court's order dismissing a claim by inventor Thomas Russell that his exclusive distributor, Zimmer, Inc., failed to use commercially reasonable efforts to sell...more

Goulston & Storrs PC

Law of the Land - Real Estate Litigation Newsletter - April 2023, Volume II, Issue II

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FEATURED ARTICLE - Efforts clauses are common in commercial agreements, including those involving real estate. Where one or both parties cannot guarantee a particular outcome, efforts clauses attempt to qualify obligations....more

Goulston & Storrs PC

Efforts Clauses - Drafter Beware

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Efforts clauses - Efforts clauses are common in commercial agreements, including those involving real estate. Where one or both parties cannot guarantee a particular outcome, efforts clauses attempt to qualify...more

BCLP

Enforcing share security: appropriation and “commercially reasonable” valuations

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The recent case of ABT Auto Investments Ltd v Aapico Investment Pte Limited and others [2022] EWHC 2839 (Comm) explores a lender’s rights to enforce share security by appropriating shares secured in its favour. The statutory...more

Goodwin

Survival Guide to Structuring Life Sciences Partnering and M+A Agreements

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The life sciences space is ever-growing and dynamic as the industry witnesses more companies and, therefore, more collaboration, licensing and M&A agreements, come into the spotlight. While these deals are exciting...more

Proskauer - The Patent Playbook

"Commercially Reasonable Efforts” Clauses in Drug Development Deals: What Level of Protection Do They Really Provide?

Pharmaceutical drug development is expensive. One recent study estimates that the median cost to develop a new drug is $985 million, while the average is $1.3 billion. And those figures appear to be on the low end of a broad...more

Hudson Cook, LLP

GIACT and Hudson Cook Break Down NACHA’s New Account Validation Rule

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Businesses using ACH will soon have to comply with a new rule, the WEB Debit Account Validation Rule, related to account validation. The effort – meant to help combat fraud and protect users – has also been a source of...more

ArentFox Schiff

Arent Fox's Stark & Anti-Kickback Statute Final Rules Analysis

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Click the link below for our complete analysis of recent updates to the Stark Law and Anti-Kickback Statute and their impact on health care providers. ...more

Goodwin

Buyer (or Seller) Beware: Who Bears the Risk with Hotel Operating Covenants in a Pandemic?

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Following a dramatic pause starting last spring, the hotel purchase and sale market has begun to show signs of a rebound. A significant challenge to these sales, however, is the remaining uncertainty around the COVID-19...more

Foley & Lardner LLP

Key Takeaways from the Revised and Clarified Stark Law Regulations – Part 1

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CMS made impactful changes to the Federal physician self-referral law’s (i.e., Stark Law’s) regulations in its Final Rule that were effective January 19, 2021 (with the exception of the changes to 42 C.F.R. § 411.352(i) that...more

Cozen O'Connor

New York Commercial Reasonability Standards in UCC Mezzanine Foreclosure Sales During COVID-19

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The COVID-19 pandemic has brought with it a host of novel legal issues, and just as nature abhors a vacuum, the legal profession abhors a lack of precedent. A case in point relates to mezzanine loan foreclosure sales under...more

ArentFox Schiff

Changes to Stark Law Definitions Impact Innovative Relationships and “Commercially Reasonable” Considerations

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The Final Rule of the Stark Law revises the definitions of Fair Market Value and includes a definition of General Market Value to better align with actual practices without unduly restricting innovative relationships between...more

Skadden, Arps, Slate, Meagher & Flom LLP

Diligence Clauses and the Management of Uncertainty in Life Sciences Agreements

In times of uncertainty and disruption, setting expectations for performance with business partners and contractual counterparties can be more complicated than ever. Companies that develop drugs, biologics and medical devices...more

Moritt Hock & Hamroff LLP

UCC Sales Held Not Subject To Cuomo Executive Order Barring Mortgage Foreclosures

A recent New York State Supreme Court judge has answered the question of whether Governor Andrew Cuomo’s Executive Order 202.8 precluding mortgage foreclosures for ninety (90) days, applies to Uniform Commercial Code (“UCC”)...more

White and Williams LLP

What’s the Standard for “Commercially Reasonable” in a Commercially Unreasonable World (Health Crisis)? Part II

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Yesterday, in a turn of events that struck a hopeful chord for mezzanine lenders, New York County Supreme Court Judge Frank P. Nervo vacated his April 30, 2020 order which temporarily halted the sale of mezzanine loan...more

White and Williams LLP

What’s the Standard for “Commercially Reasonable” in a Commercially Unreasonable World (Health Crisis)?

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On April 30, 2020, Judge Frank P. Nervo of the New York State Supreme Court, New York County, granted a temporary restraining order preventing a public sale of collateral securing a junior mezzanine loan, issuing an order...more

Bradley Arant Boult Cummings LLP

Federal Reserve Expands Scope of Main Street Lending Program and Announces New Details

On April 30, the Federal Reserve announced substantial changes to the initial terms of its Main Street Lending Program originally released on April 9, 2020: After receiving over 2,200 comment letters and consulting with...more

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