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Preserving the Corporate Attorney-Client Privilege as Against Investors

In Hyde Park Venture Partners Fund III, L.P. v. FairXchange, LLC, the Delaware Court of Chancery provided a valuable reminder to corporations and their directors and officers that a corporation cannot assert a privilege, such...more

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

Oversight Duties Apply to Corporate Officers

It is well established that corporate officers owe the same fiduciary duties as directors under Delaware law. However, the Delaware courts have not had occasion to consider every species of fiduciary duty claim against...more

Court of Chancery Strikes Down Restrictive Covenants Designed to Protect Private Equity Investments Beyond the Target

Recently, the Delaware Court of Chancery issued a decision regarding restrictive covenant agreements that will likely have an immediate impact on the scope of restrictive covenants in private equity transactions. In the...more

A Cautionary Tale About PE Principal Liability for Portfolio Company Operations

In In re P3 Health Group Holdings, LLC, the Delaware Court of Chancery held that a principal of a private equity fund was subject to jurisdiction in Delaware for alleged actions he took on behalf of one of the private equity...more

An Updated Framework for Delegating Equity Grant-Making Authority in a Delaware Public Company

Effective as of August 1, amendments to the Delaware General Corporation Law (DGCL) update the framework under which a company’s board of directors may delegate its authority to grant equity incentive awards....more

Circuit Split: Ninth And Seventh Circuits Disagree Over Enforceability of Delaware Exclusive Forum Provisions

In a recent decision, the Ninth Circuit split with a Seventh Circuit decision on the enforceability of exclusive forum provisions contained in a Delaware corporation’s certificate of incorporation or bylaws as to derivative...more

Delaware Corporations Cannot Use Their Charter to Alter the Judicial Standard of Review

In Totta v. CCSB Financial, the Court of Chancery invalidated a boards’ invocation of an anti-takeover provision in the corporation’s certificate of incorporation. It did so because the board invoked the provision to thwart...more

CFPB Addresses Credit Reporting in Buy Now Pay, Later Market

In a blog post released June 15, the Consumer Financial Protection Bureau (CFPB) continued to show its interest in credit reporting by Buy Now, Pay Later (BNPL) lenders. Recognizing the importance of credit reporting to...more

Background Screener Agrees to Resolve Class Action Over Alleged Misreporting of Criminal Convictions

On May 26, preliminary approval was sought to resolve a proposed class action, pending in the U.S. District Court for the District of Minnesota, against background screening company Inflection Risk Solutions LLC (Inflection)....more

Private Equity and Delaware Law – Part Two [Audio]

Troutman Pepper attorneys Chris Chuff and Taylor Bartholomew are well-versed in M&A transactions that involve Delaware law. In the second episode of this two-part series, Chris and Taylor discuss the rules of the road for...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

Private Equity and Delaware Law – Part One [Audio]

Troutman Pepper attorneys Chris Chuff and Taylor Bartholomew are well-versed in M&A transactions that involve Delaware law. In the first episode of this two-part series, Chris and Taylor discuss drafting considerations for...more

Delaware Court of Chancery Signals That Delaware Is a Pro-Sandbagging Jurisdiction

A recent post-trial decision from the Delaware Court of Chancery has become the latest authority in the debate over whether Delaware is or is not a “pro-sandbagging” jurisdiction. In Arwood v. AW Site Services, Vice...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

An Overview of the 2021 Amendments to the Delaware General Corporation Law and Alternative Entity Acts

On June 30, Governor Carney signed into law certain amendments (Amendments) to the Delaware General Corporation Law (DGCL), the Delaware Limited Liability Company Act (LLC Act), the Delaware Revised Uniform Partnership Act...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

Pill with 5% Trigger Too Poisonous to Address Hypothetical Stockholder Activism

Who Needs to Know - Boards of directors of Delaware corporations contemplating the adoption of a stockholder rights plan (a/k/a poison pill)....more

Buyer Beware: Untimely Delivery of Closing Statement Results in Waiver of the Right to Post-Closing Adjustments

In Schillinger Genetics, Inc. v. Benson Hill Seeds, Inc., the Delaware Court of Chancery held that plaintiff sellers were entitled to summary judgment on their claim that the buyer breached the parties’ purchase agreement by...more

Changes to Target’s Business Prompted by COVID-19 Pandemic Breached Ordinary Course Covenant, Permitting Buyer to Escape Deal

In a recent decision, the Delaware Court of Chancery permitted a buyer to escape its obligation to acquire a target from a seller under the parties’ purchase agreement because the target had made extensive changes to its...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

The Latest Successful Caremark Claim

In Teamsters Local 443 Health Services & Insurance Plan v. Chou, the Delaware Court of Chancery held, at the pleading stage, that plaintiff stockholders had stated a claim for Caremark oversight liability against certain of...more

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