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Court of Chancery Explains Conspiracy Jurisdiction and Inquiry Notice Rules

iBio v. Fraunhoffer Gesellschaft, C.A. No. 2017-0790-TMR (Del. Ch. Dec. 10, 2018) - This decision has two helpful analyses. First, it addresses the conspiracy theory of jurisdiction under the well-known Instituto Bancario...more

Court of Chancery Addresses Attorney Conduct and Sanctions

Lendus, LLC v. Goede, C.A. No. 2018-0233-SG (Del. Ch. Dec. 10, 2018) - The Court of Chancery respects zealous advocacy, but demands professionalism and degrees of civility, among counsel and the parties....more

Court Of Chancery Resolves 2 Significant Indemnification Issues

Creel v. Ecolab Inc., C.A. 12917-VCMR (October 31, 2018) - This decision resolves indemnification issues that regularly arise. First, when there are two possible indemnitors and one pays up, may the indemnitee still seek...more

Superior Court of Delaware CCLD Finds 6 Del. C. 1-308 Permits Parties to Reserve Their Rights Without Pleading Duress

Huntsman International LLC v. Dow Chemical Co., C.A. No. N17C-11-242-WCC-CCLD (Del. Super. Oct. 3, 2018) - In this decision by the Complex Commercial Litigation Division, the Court held, for the first time, that under 6...more

Court Of Chancery Interprets Preferred Stock Rights

Cedarview Opportunities Master Fund L.P. v. Spanish Broadcasting System Inc. C.A. 2017-0785-AGB (August 27, 2018) - How to interpret the provisions of preferred stock is often a difficult task. Any preference must be...more

Delaware Superior Court Narrows Jurisdiction In Mass Tort Litigation

In Re: TALC Product Liability Litigation, C.A. N17C-03-054 TAL (September 10, 2018) - This is an important decision that applies recent United States Supreme Court jurisdiction cases to a non-resident’s Delaware complaint....more

Court of Chancery Addresses Contractual Fiduciary Duties, Secondary Liability, and Banker Liability in the MLP Context

Mesirov v. Enbridge Energy Company, C.A. No. 11314-VCS (Del. Ch. Aug. 29, 2018) - This is the latest decision in a long-running saga in the master limited partnership (MLP) context involving Enbridge Energy....more

Delaware Superior Court Explains When Expert Opinion Is Admissible

The State of Delaware v. Card Complaint LLC, C.A. N13C-06-289 PRW CCLD (August 29, 2018)- This is an excellent summary of the law governing the admissibility of an expert opinion....more

Delaware Superior Court Explains Impact Of European Data Rules On Forum Motion

Ethica Corporate Finance S.r.L. v. Dana Incorporated, C.A. No. N17C-10-145 EMD CCLD (August 16, 2018) Under the Cryo-Maid decision, a forum non conveniens motion must consider the impact on a defendant forced to litigate...more

Court of Chancery Reviews Post-Closing Payments

Fortis Advisors LLC v. Stora Enso AB, C.A. No. 12291-VCS (Del. Ch. Aug. 10, 2018) - Many merger agreements provide for additional payments after closing depending on the target’s performance....more

Federal District Court Explains Incorporation By Reference Rules

Askari v. Pharmacy Corporation of America, C.A. 16-1123-RGA (D. Del. August 8, 2018) - It is not always clear when two agreements are to be read as one. This is because incorporating one agreement into a second agreement...more

Federal District Court Dismisses Contradictory Claims

Hiller & Associates LLC v. Garden Fresh Restaurants LLC, C.A. 18-152-VAC-MPT (D. Del. August 9, 2018) - This is an interesting decision because it dismisses a counterclaim that is contradicted by the claimant’s answer to...more

Delaware Superior Court Applies The McWane Doctrine

Lincoln Benefit Life Company v. Wilmington Trust N.A., C.A. N18C-01-082 EMD CCLD (July 31, 2018) - This decision has an extensive discussion of when a Delaware court will stay a matter in favor of litigation in another...more

Delaware Superior Court Explains When Fraud Claims May Survive An Integration Clause

Flowshare, LLC v. Georesults Inc., C.A. N17C-07-227 EMD CCLD (July 25, 2018) - This decision explains when a fraud claim survives a motion to dismiss that is based on the argument that an integration clause in a contract...more

Delaware Superior Court Explains Statute Of Frauds

World Class Wholesale LLC v. Star Industries Inc., C.A. N17C-05-093 MMJ (May 22,2018) - This decision explains that when a contract may be validly terminated in less than a year the statute of frauds does not apply....more

Delaware Superior Court Explains Limits Of Choice Of Law In Contracts

Change Capital Partners Fund I, LLC v. Volt Electrical Systems LLC, C.A. N17C-05-290 RNC (April 3, 2018) - This decision holds that a contractual provision adopting Delaware law will generally be upheld. ...more

Delaware Superior Court Denies Dismissal On Forum Non Conveniens

Lincoln Benefit Life Company v. Wilmington Trust N.A., C.A. N17C-08-301 ALR (April 5, 2018) - This decision holds that a case will not be dismissed on forum grounds just because it involves the interpretation of another...more

Court Of Chancery Addresses Conflicted Transaction And Secondary Liability

RCS Creditor Trust v. Schorsch, C.A. No. 2017-178-SG (Del. Ch. Apr. 5, 2018) - This is an interesting decision for two reasons. First, it distinguishes between classic self-dealing claims and tag-along challenges to...more

Court of Chancery Rejects Conspiracy Theory of Jurisdiction At Summary Judgment Stage

Reid v. Siniscalchi, C.A. No. 2874-VCS (January 30, 2018) - The facts underlying this summary judgment decision are rather remarkable. The case is long-pending, and involved years of jurisdictional discovery granted for...more

Court Of Chancery Explains When A Prediction Is A Misleading Disclosure

Chatham Asset Management LLC v. Papanier, C.A. No. 2017-0088-AGB (Dec. 22, 2017) - It is often said that a mere prediction of some future event cannot be misleading because such predictions are speculations that cannot be...more

Delaware Supreme Court Explains When Derivative Case May Be Dismissed

City of Birmingham Retirement and Relief System v. Good, No. 16, 2017 (December 15, 2017) - This decision explains again that actual or constructive knowledge of persistent corporate wrongdoing is needed before there is a...more

Delaware Supreme Court Sets A New Standard And Clarifies The Spectrum Of Forum Non Conveniens Standards

Gramercy Emerging Markets Fund v. Allied Irish Banks P.L.C., No. 49, 2017 (Oct. 27, 2017) - Under the Cryo-Maid factors, a Delaware court may dismiss a suit on forum non conveniens grounds only after the defendant shows...more

Court Of Chancery Addresses The Need For Legally-Distinct Co-Conspirators Under A Conspiracy Theory Of Jurisdiction

The general rule is that personal jurisdiction based on a conspiracy theory cannot rely on allegations of an individual officer conspiring with his corporate employer. There is a possible exception, however, when the officer...more

Court Of Chancery Explains When Side Deals Are Actionable Under A Bad Faith Theory

Kahn v. Stern, C.A. No. 12498-VCG (Aug. 28, 2017) - It is not easy to sufficiently plead a bad faith breach of fiduciary duty by a board in approving a merger when a majority of the directors were disinterested and...more

Court Of Chancery Upholds Claim Based On Low-Ball Self Tender

Buttonwood Tree Value Partners L.P. v. R.L. Polk & Co. Inc., C.A. No. 9250-VCG (July 24, 2017) - This an interesting decision because it upholds a claim that the controllers of a Delaware corporation breached their...more

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