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More Than a Majority: Chancery Court Provides Rare Guidance on Charter Amendments

It is well known that the Delaware General Corporation Law (DGCL) provides that a majority of the voting power of all stockholders entitled to vote is required for a Delaware corporation to take certain fundamental actions,...more

M&A Ruling Illustrates Limits of Disclaiming Fraud in Del.

Last month’s Fortis Advisors LLC v. Johnson & Johnson decision by the Delaware Court of Chancery makes clear that extracontractual fraud claims may only be eliminated through explicit anti-reliance provisions, not through...more

Firms Seeking Mootness Fees for Supplemental Disclosures Suffer Another Blow

In a recent order, the U.S. District Court for the Southern District of New York denied a $250,000 “mootness fee” request by a stockholder plaintiff’s counsel, arising out of an investor challenge to Microsoft’s $19.7 billion...more

Disclaiming Fraud Under Delaware Law

A recent decision by the Delaware Court of Chancery makes clear that extra-contractual fraud claims may only be eliminated through explicit anti-reliance provisions, not through other contractual mechanisms, such as exclusive...more

Upshots of Del. Holding on Appraisal Rights Waivers in M&A

In what represents a victory for private equity and venture capital investors, on Sept. 13, the Delaware Supreme Court issued a decision in Manti Holdings LLC v. Authentix Acquisition Co., confirming the enforceability of...more

Common M&A Provision Precludes Private Equity Buyer From Escaping an Aiding and Abetting Claim

In a previous alert, we discussed the Delaware Court of Chancery’s decision in In re Mindbody, Inc. Stockholders Litigation. In the decision, the court declined to dismiss breach of fiduciary duty claims against the chief...more

Appraisal Waivers Are Enforceable Under Delaware Law

On September 13, the Delaware Supreme Court issued a decision in Manti Holdings LLC v. Authentix Acquisition Co., confirming the enforceability of appraisal waivers by private contract so long as the stockholders agreeing to...more

Controlling Stockholder or Member Status Under Delaware Law – A Table of Key Decisions

Whether a stockholder of a corporation or member of a limited liability company (LLC) is a controlling stockholder or member often has a significant impact on breach of fiduciary duty actions, including those arising out of...more

Fraud on the Board II: Conflicted CEO Tilts Company Sale in PE Firm’s Favor

In In re Mindbody, Inc. Stockholders Litigation, the Delaware Court of Chancery declined to dismiss breach of fiduciary duty claims against the chief executive officer of MINDBODY, Inc. (the Company) arising out of the...more

Fraud on the Board: Material Conflicts Must Be Disclosed to the Board to Warrant Business Judgment Review

A recent decision by the Delaware Supreme Court emphasizes the importance of fully disclosing material director and officer conflicts of interest in connection with proposed M&A transactions. Indeed, as the Court’s ruling...more

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