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Post-Election Regulatory Changes to Corporate Governance Mirror Broader Political Shift

Significant post-election shifts in corporate governance policy are already occurring among regulators, self-regulatory organizations and proxy advisors. The SEC will no longer litigate its climate disclosure rules,...more

No Toll for Corporations Leaving Delaware on a Clear Day

Delaware Supreme Court holds business judgment rule applies to decision to reincorporate a company out of Delaware made on a “clear day.” For a non-ratable benefit to give rise to a conflict and trigger entire fairness,...more

Delaware Supreme Court Reaffirms High Bar for Proving Control by a Minority Stockholder

Delaware Supreme Court reaffirms that “the test for actual control by a minority stockholder is not an easy one to satisfy.” Supreme Court makes clear that control by a minority stockholder is “not presumed.” Supreme Court’s...more

Fifth Circuit Strikes Down Nasdaq Diversity Disclosure Rule

By a 9-8 majority, the Fifth Circuit Court of Appeals struck down the rule proposed by Nasdaq and approved by the SEC requiring most Nasdaq-listed companies to either maintain at least two diverse directors on the board or...more

Delaware Court of Chancery Rules No Supermajority for Nevada Reincorporation

Court of Chancery rejects claim that certificate of incorporation of a Delaware corporation requires supermajority vote for conversion to a Nevada corporation. Court holds that certificate provision requiring...more

Delaware Court of Chancery Emphasizes the High Burden of Pleading Oversight Claim

Court of Chancery rejects Plaintiffs’ claims that directors engaged in “affirmative lawbreaking for profit”, finding alleged “trifling or technical” violations are ones “over which reasonable minds can differ.” Court...more

After Delaware Court of Chancery Subjects Reincorporation Decision to Entire Fairness, Delaware Supreme Court Says Not so Fast

The Delaware Court of Chancery issued an order in Palkon v. Maffei on February 20, 2024, holding that a decision by the boards of directors and the controller of TripAdvisor, Inc. (“TripAdvisor”) and Liberty TripAdvisor...more

SEC Adopts Final, Comprehensive Climate Disclosure Rules

On March 6, 2024, the U.S. Securities and Exchange Commission (the “SEC”) adopted on a 3-2 vote its long-awaited, comprehensive rules for enhancing and standardizing climate-related disclosures by public companies in periodic...more

Delaware Court of Chancery’s Rescission of Elon Musk’s US$55.8 Billion Pay Package Signals Expansion of Scrutiny into Potential...

The Delaware Court of Chancery issued a post-trial opinion, on January 30, 2024, in Tornetta v. Musk, holding that Tesla’s board of directors (the “Board”) breached its fiduciary duties in awarding CEO Elon Musk (with the...more

Business Coalition Sues California to Block New Climate Disclosure Laws

On January 30, 2024, the U.S. Chamber of Commerce and five co-plaintiffs representing a coalition of business groups filed a lawsuit against the California Air Resources Board (“CARB”), an agency of the State of California...more

Caremark Claim Based on Business Risks Dismissed

The Court of Chancery continues its consideration of whether a director or officer’s oversight duties, set forth in the seminal case of In re Caremark International Inc. Derivative Litigation and its progeny, apply to...more

SEC Finalizes Amendments Governing Beneficial Ownership Reporting

Revised deadlines for initial Schedule 13D and Schedule 13G filings: Schedule 13D: within five business days (rather than 10 calendar days) after crossing the 5% beneficial ownership threshold or losing eligibility to file...more

California Governor Signs Climate Disclosure Bills with Significant Impact for Entities of All Forms Doing Business in the State

The two new California laws apply to both public and private corporations, partnerships, limited liability companies, or other business entities meeting applicable revenue thresholds and doing business in California, without...more

Delaware Court of Chancery Bars Stockholder from Inspecting Books and Records Related to Board’s ESG-Related Decision

Proof that an inspection demand is improperly “lawyer-driven” will overcome a stockholder’s pretextual claim for investigating wrongdoing. A stockholder does not have a proper purpose for investigating an “ordinary...more

The Developing Litigation Risks from the ESG Backlash in the United States

In the past year, environmental, social, and governance (“ESG”) practices have faced heightened scrutiny in the United States from state attorneys general, state and federal legislators, other government officials, and...more

SEC Proposes Comprehensive Climate-Related Disclosure Rules

On March 21, 2022, the U.S. Securities and Exchange Commission (the “SEC”) released its new and longanticipated proposed rules for the enhancement and standardization of climate-related disclosures. The proposed rule...more

International Capital Markets Newsletter: The ESG Edition - June 2021 – Issue 4: SEC’s Recent Pronouncements on ESG and Other...

That the meaning of “ESG” no longer needs to be explained, illustrating how important these issues have become to investors, public companies, international capital markets and, correspondingly, the U.S. Securities and...more

NASDAQ Proposes Revisions to Shareholder Approval Rules

Nasdaq, Inc. recently requested comments regarding possible updates to its “20% voting rule.” That rule, adopted in 1990, requires Nasdaq listed companies to obtain shareholder approval when issuing 20% or more of its stock...more

IPOs - Attractive Exit Alternative For Financial Sponsors

The strong U.S. initial public offering (IPO) market, coupled with favorable regulatory changes and market acceptance of innovative transaction structures, has increased the attractiveness of the IPO as an exit alternative to...more

DOJ and SEC Scrutinize Potential Misuse of Rule 10b5-1 Trading Plans by Corporate Directors Affiliated with Investment Advisers

Over the past four years, the U.S. Department of Justice (“DOJ”) and U.S. Securities and Exchange Commission (“SEC”) have focused on insider trading involving private funds as one of their key targets in the fight against...more

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