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Go-Shop Provisions

Delaware Supreme Court Reaffirms Director Protections in Change of Control Context

March 31, 2009 | Posted by | Topic(s): Fiduciary Duties, Go-Shop Provisions, Advisories

his advisory discusses the Delaware Supreme Court's highly anticipated decision in the case of Lyondell Chemical Company et al., v. Ryan. The denial of summary judgment by the Chancery Court had given rise to serious concerns that monetary liability for directors based upon violations of the duty of good faith in a sale of corporate control was much more likely than previously thought. In reversing the Chancery Court and entering summary judgment for the directors, the Supreme Court reaffirmed its previous decisions outlining the contours of the duty of good faith, and provided welcome comfort to directors and their advisors as they consider how to fulfill directors' fiduciary duties relating to change of control transactions.

The advisory is provided in PDF on the Alston & Bird website: http://www.alston.com/corporate_governance_advisory_protections

Board’s Hasty Approval of Merger May Violate Revlon Duties and Constitute Bad Faith

August 13, 2008 | Posted by | Topic(s): Fiduciary Duties, Go-Shop Provisions, Advisories

This advisory discusses the Delaware Court of Chancery’s recent denial of summary judgment to directors who approved a merger transaction in just seven days, and without conducting an active pre-signing or post-signing market check, even though the only bidder offered a “blowout” price. Moreover, given the board’s failure to take an active role in negotiating the merger and in informing itself of the value of the company, the court held that the directors could not benefit from the exculpatory provision in the company’s charter at the summary judgment stage because they may have breached their duty of loyalty by acting in bad faith.

The advisory is provided in PDF on the Alston & Bird Web site: http://www.alston.com/seclit_advisory_merger_revlon