A Look Back
Appraisal Rights
DECEMBER 8, 2017
Eight years ago today, in DiRienzo v. Steel Partners Holdings L.P. , No. 4506-CC (Del. Ch. Dec. 8, 2009), Chancellor Chandler reaffirmed the principle that the record holder requirements of Section 262(a) demand strict compliance. The Chancery Court dismissed an appraisal petition on grounds that the appraisal demand was not made by a record holder listed on the company’s stock ledger.
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