News & Analysis as of

Delaware Limited Liability Company (LLC)

Troutman Pepper Locke

Delaware Court of Chancery Invalidates Noncompete Provision Found in Typical Sponsor Equity Documents

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In Weil Holdings II, LLC, v. Jeffrey Alexander, DPM, the Delaware Court of Chancery struck down a noncompete provision contained in the LLC agreement of a sponsor-backed portfolio company, finding the provision unreasonable...more

Dorsey & Whitney LLP

2025 Delaware Entity Statutory Amendments

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On August 1st, the 2025 amendments to Delaware’s entity statutes went into effect. These include amendments to the Delaware General Corporation Law (the “DGCL”), the Delaware Limited Liability Company Act (the “LLC Act”), the...more

McCarter & English, LLP

Recent Amendments to Delaware Alternative Entity Statutes

On August 1, 2025, legislation went into effect amending the Delaware Limited Liability Company Act (the LLC Act), the Delaware Revised Uniform Limited Partnership Act (the LP Act), and the Delaware Revised Uniform...more

Cadwalader, Wickersham & Taft LLP

No Need to Pile On: Delaware Court of Chancery Rejects LLC Books and Records Demand After Unitholder’s Months-Long Investigation

In a recent decision, Thomas J. Scaramellino v. Arencibia Holdco, LLC, the Delaware Court of Chancery refused to allow the unitholder of a Delaware LLC to access “informal” LLC books and records—email, text messages, Slack,...more

Morris James LLP

Chancery Orders Confidential Treatment of Member List Produced in Books and Records Action

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Garlington v. Two Rivers Farm, LLC, C.A. No. 2024-0917-BWD (Del. Ch. Apr. 7, 2025) - The Court of Chancery entered default judgment in a books and records action. The defendant limited liability company then appeared...more

Morris James LLP

Chancery Upholds Expulsion of LLC Investor, Awards Fees and Expenses Caused by Breach

Morris James LLP on

PJT Holdings, LLC v. Costanzo, C.A. No. 2023-0665-JTL (Del. Ch. May 15, 2025) - In anticipation of launching a chain of restaurants, three restaurant operators joined an outside investor to form a four-member,...more

Husch Blackwell LLP

Recent Changes to Texas Corporate Laws Could Make the State a More Attractive Choice for Entity Formation and Re-domestication of...

Husch Blackwell LLP on

The Texas legislature concluded its 89th Regular Session on June 2, 2025. During the session, the energy industry paid significant attention to legislative actions impacting the power industry in the areas of grid management,...more

Bodman

Update: New Requirements for Delaware Assumed Name Filings Include Mandatory Re-Registration of Trade Names

Bodman on

Pursuant to House Bill 177, Delaware has postponed the effective date of the changes to its trade name registration process until February 2, 2026, to “allow the Department of Revenue to conduct outreach to affected agencies...more

Troutman Pepper Locke

Delaware Court of Chancery Allows Amendment of LLC Agreement to Permit Disparate Consideration Where Amendment Provisions Were...

Troutman Pepper Locke on

In Faiz Khan and Ralph Finger v. Warburg Pincus, LLC et al., the Delaware Court of Chancery held that the implied covenant of good faith and fair dealing was not applicable to a private equity sponsor’s amendment of a limited...more

Ballard Spahr LLP

DE Chancery Court Curbs Inspection to Investigate Alleged Fraud

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In Scaramellino v. Arencibia Holdco, LLC, Delaware’s Chancery Court recently approved a limited liability company’s narrow production in response to a broad books and records inspection demand, despite the petitioner’s...more

Morgan Lewis

Changes in Delaware Trade Name and DBA Registrations Slated for Early 2026

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Effective February 2, 2026, significant changes will be implemented in the process of registering fictitious names, trade names, and doing business as names (collectively trade names) in Delaware. These changes are designed...more

Bodman

New Requirements for Delaware Assumed Name Filings Include Mandatory Re-Registration of Trade Names

Bodman on

Beginning June 2, 2025, Delaware will no longer require companies to file notarized trade names (also known as “doing business as” or “DBA” names) in each county. Instead, companies will need to complete a single online...more

Morris James LLP

Chancery Rejects Attempt to Disguise Breach of Fiduciary Duty Claim Where LLC Agreement Waived All Traditional Fiduciary Duties

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Delaware permits the elimination of fiduciary duties in limited liability company agreements. Notwithstanding, and just like in any other contract, parties to a limited liability company agreement are still subject to the...more

Husch Blackwell LLP

Delaware Overhauls DBA Process

Husch Blackwell LLP on

On February 7, 2025, Delaware House Bill 40, which amends portions of the Delaware Code dealing with the registration of trade names (DBAs) in Delaware, was signed into law by Governor Matt Meyer. ...more

Patton Sullivan Brodehl LLP

You Come at the LLC Manager, You Best Not Miss

In a popular TV series (The Wire), a well-known quote is: “You come at the king, you best not miss.” The idea is that if you’re taking the risk of attacking someone at the top, you better not miss your shot....more

Allen Matkins

Another Court Conflates Limited Liability Companies And Corporations

Allen Matkins on

For the last several years, I have been commenting on the judicial confounding of limited liability companies and corporations. Recently, I came across yet another egregious mergence of the corporate and LLC forms...more

Vinson & Elkins LLP

Delaware Court of Chancery Dismisses Claims Relating to Sale of Company Against Private Equity Majority Owner

Vinson & Elkins LLP on

In the latest instance of a private equity seller vindicating contractual rights in the Delaware Court of Chancery, on April 30, Vice Chancellor Lori W. Will rejected attempts by minority LLC members in urgent care provider...more

Mayer Brown

Delaware Law Alert: Chancery Court Dismisses Challenge to Elimination of Tag-Along Rights in Private Equity-Backed Healthcare...

Mayer Brown on

A recent Delaware Chancery Court decision provides important guidance for private equity sponsors, minority investors, and deal professionals regarding the enforceability of contractual waivers and the limits of the implied...more

Goldberg Segalla

Defendant’s Motion to Dismiss Reversed by Court of Appeals of Indiana

Goldberg Segalla on

Jurisdiction: Court of Appeals of Indiana - In this asbestos action, it was alleged that decedent, Ronald McBride had asbestos exposure from the use of asbestos-containing talcum powder products while living in Indiana and...more

Cadwalader, Wickersham & Taft LLP

The Impact of In re 301 W N. Ave., LLC on the Enforcement of Bankruptcy-Remote Protections

Executive Summary - The recent decision In re 301 W N. Ave., LLC, 666 B.R. 583 (Bankr. N.D. Ill. 2025) represents a significant development at the intersection of corporate governance, commercial real estate, and...more

Morris James LLP

Chancery Finds Merger Validly Amended LLC Agreement and Effectively Removed the LLC’s Manager

Morris James LLP on

Campus Eye Management Holdings LLC v. DiDonato, C.A. No. 2024-0121-LWW (Del. Ch. Aug. 30, 2024) - This case arose out of a dispute between an optometrist who sold a majority stake in his company to a private equity buyer,...more

Morris James LLP

Chancery Holds Defendant Breached Fiduciary Duties by Failing to Distribute Assets Equally During Dissolution of LLC

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Mehra v. Teller, C.A. No. 2019-0812-KSJM (Del. Ch. Sept. 20, 2024) - In this post-trial decision, the plaintiffs claimed that one of the defendants breached his fiduciary duties by failing to distribute assets equally at...more

Farrell Fritz, P.C.

New York Top Court’s Advice to Prospective Investors in Delaware LLCs: Pay Close Attention to Controller’s Power to Amend LLC...

Farrell Fritz, P.C. on

Opinions by the Court of Appeals, New York’s highest court, construing the state’s LLC Law enacted 30 years ago are almost but not quite as rare as hen’s teeth. The great majority of important rulings under the statute...more

Morris James LLP

Chancery Says Litigation Privilege No Shield Against LLC Interest Repurchase

Morris James LLP on

Seva Holdings Inc. v. Octo Platform Equity Holdings, LLC, C.A. No. 2022-0437-PWR (Del. Ch. Aug. 29, 2024) - In deciding limited cross motions for summary judgment, the Court of Chancery held that the absolute litigation...more

Morris James LLP

Key Takeaways from Recent Delaware Restrictive Covenant Case Law

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Partners Vincent Cannizzaro and Barnaby Grzaslewicz recently presented Recent Developments in Delaware Restrictive Covenant Case Law: The Alternative Entity Creep, providing key insights into how Delaware’s courts are...more

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