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After More Than A Year, Questions Remain Regarding Caremark and Officers

Last year, Vice Chancellor J. Travis Laster famously held that officers could be subject to liability under the Caremark doctrine.  In re McDonald’s Corp., 289 A.3d 343 (Del. Ch. Jan. 26, 2023).    The Caremark doctrine...more

Foreign Corporations Filing Actions In California May Be Required To Post Bonds When Domestic Corporations Are Not

Under Section 1030 of the California Code of Civil Procedure, a defendant may at any time apply to the court by noticed motion for an order requiring the plaintiff to file an undertaking to secure an award of costs and...more

When Two Corporate Laws Diverge, Does Choosing One Make All The Difference?

In a new article, professor of law Wendy Gerwick Couture aims for "a fuller understanding of Nevada corporate law, both substantively and theoretically, as compared with Delaware corporate law".  For the title and them of her...more

The Importance Of Calling

The validity of a board meeting hinges on three things - a quorum, notice and call.  Many lawyers focus on the first two and may overlook the third.   For California and Nevada corporations, the question of who may call a...more

Is A Change In Transfer Restrictions In A Shareholder Agreement Subject To Qualification?

A recent post discussed whether amending a shareholders agreement is subject to qualification under the California Corporate Securities Law of 1968.  For the purpose of that discussion, it is important to recognize that not...more

Another Delaware Corporation Announces Stockholder Approval Of Nevada Reincorporation

I continue to be on the lookout for Delaware corporations that have made the decision to reincorporate in Nevada.  Last Friday, Elevai Labs Inc. filed a preliminary information statement with the Securities and Exchange...more

Does Amending A Shareholders Agreement Require Qualification Under The California Corporate Securities Law?

A significant amount of background is required to answer the question of whether amending a shareholders agreement is subject to qualification under the California Corporate Securities Law.  As an initial matter, the CSL...more

Is Nevada's Corporate Law "One Of The Most Comprehensive And Progressive State Corporate Acts"?

In May, I took note of this Form 8-K filed by P.A.M. Transporation Services, Inc. announcing board approval of a plan to convert the company's state of incorporation from Delaware to Nevada.  The company has now filed...more

Cave Delaware Aut Bene Dormi Delaware?

I began writing about Nevada Corporate Law more than three decades ago with an article entitled "The Nevada Corporation: Is It A Good Bet?".  14 CEB California Business Law Reporter 259 (1992).  In the ensuing decades, I have...more

Professor Bainbridge Queries Whether SB 313 Eviscerates Omnicare, But Does That Question Have Any Relevance To California...

Delaware practitioners and legal scholars are digesting the implications of SB 313 which adds a new Section 122(18) to the Delaware General Corporation.  According to the bill's synopsis, this new provision...more

California Decides That The Sun Shall Not Set On Virtual Meeting Statutes

Despite being home to the Silicon Valley, California has not embraced with abandon virtual-only meetings of shareholders.  Section 600(e) of the Corporations Code currently does not permit virtual only meetings unless one of...more

Nevada's Secretary Of State Urges Delaware Supreme Court To Eschew "Exit Tax"

In a May post, I observed: As a long-time beneficiary of corporations fleeing other jurisdictions, Delaware may be tempted to put the brakes on its own corporations wishing to flee to the sunny uplands of other states. ...more

Israel Headquarted Company Approves Move From Delaware To Nevada

As the debate continues regarding DExit, I have been on the lookout for companies making the move from Delaware to Nevada.  Recently, I came across this information statement filed by Viewbix Inc., a digital advertising...more

What About Calexit?

My last several posts have discussed the current debate on the phenomenon referred to as "DExit", which refers to Delaware corporations that choose to reincorporate in other states.  In a recent article, Professor Bainbridge...more

Do Nevada Courts Ignore Delaware Precedents?

In a recently released article, Professor Stephen Bainbridge tackles the question of just how real the DExit phenomenon might really be.  Among other things, he responds to my argument that Nevada eschews Delaware law...more

DExit - Would Oliver Cromwell Reincorporate In Nevada?

Yesterday's post highlighted Professor Stephen Bainbridge's recently posted article, DExit Drivers: Is Delaware's Dominance Threatened?  His article analyzes the reasons that companies give for leaving Delaware for other...more

Professor Bainbridge's DExit Exegesis

A year ago, Phil Shawe, the Chief Executive Officer of TransPerfect, penned a piece for The Nevada Independent explaining the company's reincorporation from Delaware to Nevada...more

Is A Notitia Congregationis Valid In California?

California is a very linguistically diverse state with an estimated 200 plus different languages being spoken.  Within my own family, English is not the primary language spoken at home by any of my grandchildren.  Yet, the...more

Court Holds Internal Affairs Doctrine Typically Covers Breach Of Fiduciary Claims Despite No Averment Of Fiduciary Duty

California's Revised Uniform Limited Liability Company Act provides "The law of the state . . . under which a foreign limited liability company is formed governs all of the following: The organization of the limited liability...more

Another Publicly Traded Delaware Corporation Propose Move To Nevada

I recently came across another publicly traded Delaware corporation with plans to reincorporate in Nevada.  Interestingly, this corporation, Sonoma Pharmaceuticals, Inc., originally began as a California corporation and then...more

Directors Removing Directors

Seven years ago, I addressed the question of whether the board of directors of a California corporation could remove a fellow director...more

Can Shareholders Elect Corporate Officers?

The classic model of corporate governance is that the board of directors appoints and removes the principal corporate officers.  This is consistent with the general principle that the business and affairs of a corporation...more

Knowingly Offering A False Annual Statement For Filing With The Secretary Of State Is A Felony

The Statement of Information required pursuant to California Corporations Code Section 1502 is not required to be signed under penalty of perjury.  However, the statute does require that the corporation (not the individual...more

Does Revlon Make Nevada Tense?

In Revlon, Inc. v. MacAndrews & Forbes Holdings, Inc., 506 A.2d 173, 182 (1986), the Delaware Supreme Court famously held that when the sale of a corporation becomes inevitable,  the board of directors' duty changed from the...more

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