The Delaware Court of Chancery recently delivered the latest in a line of decisions refining the application of statutory stockholder appraisal rights in M&A transactions. In City of North Miami Beach General Employees’ Retirement Plan v. Dr Pepper Snapple Group, Inc. (Del. Ch. June 1, 2018) (“Dr Pepper”), the court declined to extend the Delaware appraisal statute to apply to a change–of–control transaction that technically fell outside the strict parameters of the statute – even though the transaction economically resembled a typical public company acquisition.
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