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Lebanon County Employees’ Retirement Fund v. Collis: Guidance into timeliness of derivative claims

In Lebanon County Employees’ Retirement Fund v. Collis, C.A. No. 2021-1118-JTL (Del. Ch. Dec. 15, 2022), the Delaware Court of Chancery denied a motion to dismiss as untimely a derivative action against a pharmaceutical...more

SolarWinds: Caremark liability rejected in cybersecurity oversight claim Corporate / M&A Decisions update series

In Construction Industry Laborers Pension Fund v. Bingle, (C.A. No. 2021-0940-SG (Del. Ch. Sept. 6, 2022)) (SolarWinds), the Delaware Court of Chancery granted a motion to dismiss a derivative suit against the directors of...more

In re Carvana: Demand is futile when directors are “thick as thieves” with beneficiary of misconduct

The Delaware Court of Chancery, in In re Carvana Co., No. 2020-0415-KSJM (Del. Ch. June 30, 2022), applied the recently adopted Zuckerberg test for demand futility and denied the defendants’ motion to dismiss. The court found...more

Hamrock: No Caremark liability for natural gas explosion

In City of Detroit Police & Fire Ret. Sys. on Behalf of NiSource, Inc. v. Hamrock, No. CV 2021-0370-KSJM, the Delaware Court of Chancery granted a motion to dismiss duty of oversight claims against an energy company’s...more

Q4 2021 Quarterly Corporate / M&A decisions updates

Below is our Corporate / M&A decisions update covering decisions in the fourth quarter of 2021. This update is designed to highlight selected important M&A, corporate, and commercial court decisions on a quarterly basis....more

In re Kraft Heinz Company Derivative Litigation: Plaintiffs fail to plead demand futility - Quarterly Corporate / M&A Decisions...

In re Kraft Heinz Company Derivative Litigation addresses demand futility in a case involving an insider stock sale. 3G Capital, Inc., a 24.2 percent shareholder in Kraft Heinz, sold 7 percent of its stake in August 2018...more

United Food & Com. Workers Union v. Zuckerberg: Exculpatory clause does not render demand futile

In United Food & Com. Workers Union v. Zuckerberg, No. 404, 2020 (Del. Sup. Sep. 23, 2021), the Delaware Supreme Court adopted a new, three-part test for determining when a shareholder is required to make a pre-suit demand on...more

In re Tilray, Inc. Reorg. Litigation: DE court finds founding members to be control group - Corporate / M&A Decisions update...

In In re Tilray, Inc. Reorganization Litigation (C.A. No. 2020-137-KSJM (Del. Ch. June 1, 2021)), the minority shareholders of Tilray, Inc. alleged that the defendants breached their fiduciary duties by entering a...more

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