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Has Professor Solomon Rebutted Vice Chancellor's Theory Of Damages In Palkon v. Maffei?

Palkon v. Maffei, 311 A.3d 255 (Del. Ch. 2024), cert. denied, No. 2023-0449-JTL, 2024 WL 1211688 (Del. Ch. Mar. 21, 2024) involved a challenge to the proposed reincorporation of TripAdvisor, Inc. from Delaware to Nevada. ...more

In Proposing Move From Delaware To Nevada, This Corporation Cites The Burden Of MFW

Earlier this week, The Trade Desk, Inc. filed preliminary proxy materials for a special meeting of stockholders.  The purpose of the meeting is to approve the reincorporation of the corporation from the State of Delaware to...more

Does Combining Legal And Secretarial Roles Reduce Risk?

The California General Corporation Law requires that a California corporation have a secretary.  Cal. Corp. Code § 312(a)(2).  The CGCL, however, says nothing about a chief legal officer.  Indeed, many corporations do not...more

The One Where Everyone Got The Statute Wrong

In yesterday's post, I discussed the Court of Appeal's unpublished opinion in Milks v. Affirmed Techs., LLC,  2024 WL 1502944 (Cal. Ct. App. Apr. 5, 2024), reh'g denied (Apr. 30, 2024).  That case involved claims against a...more

A California LLC Endures Forever, A Nevada LLC Not So Long

California's Revised Uniform Limited Liability Company Act endows limited liability companies with a certain level immortality.  Corporations Code Section 17707.06(a) provides...more

Brutus Was An Honorable Man But Was He Also A Stupid One?

Today's post is a digression into Roman history and etymology, two of my long-time interests....more

The Attorney-Client Privilege In M&A Transactions - A Decade Later

In 2013, then Chancellor Leo Strine determined that under Section 259 of the Delaware General Corporation Law the attorney-client privilege held by the target company follows to the surviving company after a merger.   Great...more

California May Soon Define "Corporation" To Include That Are Not Corporations

The California Corporations Code is a misnomer.  While the Corporations Code does in fact govern corporations, it also governs a wide variety of unincorporated entities, including general partnerships, limited partnerships,...more

Another Delaware Publicly Traded Company Proposes A Nevada Move

Last week, Chromocell Therapeutics Corporation filed preliminary proxy materials that included a proposal to reincorporate in Nevada.  Rather than convert, the company is proposing to effect the reincorporation by means of a...more

Is Your Directors And Officers Liability Coverage Illusory?

Many corporations pay significant amounts for directors and officers liability policies.  Commonly referred to as D&O policies, these policies usually involve three sides.  Directors and officers are likely to have the most...more

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

Still More On Whether The SEC Exceeded Its Authority In Adopting Rule 21F-17

Yesterday's post again discussed whether the Securities and Exchange Commission exceeded its authority in adopting Rule 21F-17(a), which provides...more

SEC Settles More Rule 21F-17(a) Cases, But Has It Exceeded Its Authority?

In a blog post this morning, Liz Dunshee notes that the Securities and Exchange Commission has recently announced the settlement seven more cases involving Rule 21F-17(a), which provides...more

California Court Upholds Daily Transaction Limits On Bitcoin ATMs

A year ago, Governor Gavin Newsom signed two bills,  Assembly Bill 39 and Senate Bill 401, that created the California Digital Financial Assets Law.  SB 401 added Section 3902 to the Financial Code to prohibit an operator of...more

Does The SEC's Jurisdiction Really Extend To Any Person?

Last week, the Securities and Exchange Commission announced that it had settled charges against a broker-dealer and two investment advisers for impeding their clients from reporting securities law violations to the SEC. ...more

Looking For A Drink At 3 A.M.? Soon, You May Find One Here

California law provides that any licensee of the Department of Alcoholic Beverage Control or agent or employee of the licensee, who sells, gives or delivers to any person any alcoholic beverage between the hours of 2 a.m. and...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

California Caps Legislative Session By Sending A Weird Hedge Fund Bill To The Governor For A Possible Signature

Last month, I commented on the "weird" definition of "hedge fund" in AB 3129 (Wood).  On the last day of the current session, the legislature passed the bill.  It is now on Governor Newsom's desk....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

Why Taking A Doughnut, A Danish, and A Bagel Might Or Might Not Invite Gluttony - How Should The List Of Exceptions In Section...

Yesterday's post concerned the exemption from the qualification requirement of the California Corporate Securities Law for most changes in the rights, preferences, privileges, or restrictions of outstanding securities found...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

California Court Opines On Fiduciary Duties Of LLC Members And Covenants Not To Compete

Yesterday, the Fourth District Court of Appeal issued a noteworthy opinion addressing at least two significant questions.  Samuelian v. Life Generations Healthcare, LLC, 2024 WL 3878448....more

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