On August 5, 2016, plaintiff Temple-Inland Inc. and defendants Delaware Secretary of Finance, State Escheator and Abandoned Property Audit Manager filed a joint motion to dismiss with prejudice the Temple-Inland Inc. v. Cook, No. 1:14-cv-00654, action. The motion to dismiss was filed pursuant to a voluntary settlement agreement, which puts to rest Temple-Inland’s claims arising out of Delaware’s controversial estimation methodology, and comes just over a month after the U.S. District Court for the District of Delaware found that Delaware’s estimation practices violated due process. The decision to dismiss the action is disappointing for those that hoped for a decision from the Third Circuit once and for all striking down Delaware’s current estimation practices as unconstitutional. Nevertheless, the voluntary settlement agreement is very good news for holders, especially those that are currently under audit or participating in a voluntary disclosure agreement with the state.