{"id":684,"date":"2015-11-09T14:34:06","date_gmt":"2015-11-09T19:34:06","guid":{"rendered":"https:\/\/www2.law.temple.edu\/10q\/?p=684"},"modified":"2015-11-09T14:34:06","modified_gmt":"2015-11-09T19:34:06","slug":"increased-judicial-scrutiny-of-non-monetary-settlements-of-merger-litigation-threatens-business-model-of-some-plaintiffs-lawyers","status":"publish","type":"post","link":"https:\/\/law.temple.edu\/10q\/increased-judicial-scrutiny-of-non-monetary-settlements-of-merger-litigation-threatens-business-model-of-some-plaintiffs-lawyers\/","title":{"rendered":"Increased Judicial Scrutiny of Non-Monetary Settlements of Merger Litigation Threatens Business Model of Some Plaintiffs\u2019 Lawyers"},"content":{"rendered":"

In recent years, the percentage of corporate mergers and acquisitions challenged through stockholder litigation has more than doubled. In 2007, 44% of deals valued over $100 million were the subject of stockholder lawsuits; by 2014, the number was 93%.[1]<\/a> Merger litigation has become both reflexive and ubiquitous; plaintiffs\u2019 lawyers often file complaints on behalf of stockholders within days of the public announcement of a merger, with little or no pre-suit investigation. Many of these lawsuits are accompanied by requests for preliminary injunctive relief, typically targeting allegedly inadequate disclosures as the source of purported imminent and irreparable harm, together with attending applications for expedited treatment, as to which the applicable standard is quite low.[2]<\/a> Thus, even though the suit may lack merit either as to the allegedly deficient disclosures, the fairness of the process leading to the merger, or both, such applications create a troublesome and untimely distraction to merging parties focused on closing. There is thus reason for defendants to consider a quick settlement that will resolve the litigation in its entirety, and secure a wide-ranging release of claims in exchange for nothing more than the inclusion of additional disclosures in the target company\u2019s proxy statement.<\/p>\n

The prospect of such a resolution can give rise to conflicts for class counsel.[3]<\/a> While stockholders typically will receive no payment in exchange for the accompanying release of the claims,[4]<\/a> the lawyers that represent them almost certainly will, with the amount of such fee determined by the court\u2019s evaluation of the materiality of the supplemental disclosures and informed by the extent to which defendants are willing to withhold objection. In some instances, plaintiffs\u2019 counsel has enjoyed awards in the millions of dollars. Seldom have they amounted to less than several hundreds of thousands of dollars, often for relatively little work and in connection with relatively unimportant supplemental information.<\/p>\n

Concerned by the proliferation of merger litigation, and the increasingly cynical approach to the interests of the plaintiff class, the Court recently served notice that it will be applying greater scrutiny to non-monetary settlements.<\/p><\/blockquote>\n

Over the years, the Delaware Court of Chancery has frequently expressed its disdain for these settlements, particularly in their most transparent form. Only infrequently, however, have arrangements of this sort been flatly rejected, though approval has been accompanied from time to time by derisive observations about the nature of plaintiffs\u2019 investigation, the breadth of the release, and the questionable benefits conferred on the stockholder class. As a result, filing suits to obtain such settlements has become a business model for many plaintiffs\u2019 firms.<\/p>\n

In more recent years, however, that litigation model has been subjected to increasing scrutiny and criticism on the part of the Court of Chancery. Concerned by the proliferation of merger litigation, and the increasingly cynical approach to the interests of the plaintiff class, the Court recently served notice that it will be applying greater scrutiny to non-monetary settlements and related requests by plaintiffs\u2019 counsel for attorneys\u2019 fees where the non-monetary relief obtained for the plaintiff class of stockholders is of negligible value, particularly when compared to the global scope of the release of claims to be provided to the defendants. The Court has rejected several such settlements.[5]<\/a> As explained by one member of the Court of Chancery in rejecting a proposed non-monetary settlement, the proliferation of merger litigation\u00a0\u201cundercuts Delaware\u2019s credibility as an honest broker in the legal realm\u201d and the \u201croutine approval of [non-monetary] settlements carries real consequences, all of them bad.\u201d[6]<\/a> In other instances, in which approval of a settlement was secured by a narrow margin, the Court has cautioned that the parties should not continue to assume that approval will be forthcoming, and forewarned of significantly reduced attorneys\u2019 fees for plaintiffs\u2019 counsel in the future.[7]<\/a> As one Vice Chancellor put it, litigants can no longer rely on \u201cformerly<\/em> settled practice in this Court.\u201d[8]<\/a><\/p>\n

It remains to be seen whether the Court\u2019s approach will be sufficiently rigorous and consistent to have the desired effect: the reduction of baseless lawsuits motivated primarily by the hope of a quick and lucrative (to plaintiffs\u2019 counsel) resolution. To be sure, it appears clear that, in such circumstances, the proponents of quick, non-monetary settlements will have a more difficult task convincing the Court that their efforts are sufficient to justify dismissal or to warrant a substantial fee.<\/p>\n

\n

The views expressed by the authors are not necessarily the views of Potter\u00a0Anderson & Corroon LLP or any of its clients.<\/em><\/p>\n

[1]<\/a> Cornerstone Research, Shareholder Litigation Involving Acquisitions of Public Companies<\/em>, Review of 2014 M&A Litigation <\/em>(\u201cCornerstone Report\u201d), p. 1 (Feb. 25, 2015).<\/p>\n

[2]<\/a> See, e.g., Box v. Box<\/em>, 697 A.2d 395, 399 (Del. 1997); Giammargo v. Snapple Beverage Corp.,<\/em> 1994 WL 672698, at *2 (Del. Ch. Nov. 15, 1994).<\/p>\n

[3]<\/a> See, e.g., In re Riverbed Tech., Inc. S\u2019holders Litig.<\/em>, C.A. No. 10484-VCG (Del. Ch. Sept. 17, 2015) (Mem. Op. at 7-8).<\/p>\n

[4]<\/a> See <\/em>Cornerstone Report, p. 1.<\/p>\n

[5]<\/a> See, e.g., In re Transatlantic Holdings Inc. S\u2019holders Litig.<\/em>, C.A. No. 6574-CS, 2013 WL 1191738 (Del. Ch. Mar.\u00a08, 2013); In re Medicis Pharm. Corp. S\u2019holders Litig.<\/em>, Consol. C.A. No.\u00a07857-CS (Del. Ch. Feb. 26, 2014) (Transcript); Haverhill Ret. Sys. v. Asali<\/em>, C.A. No. 9474-VCL (Del. Ch. June 8, 2015) (Transcript); Acevedo v. Aeroflex Holding Corp.<\/em>, C.A. No. 7930-VCL (Del. Ch. July 8, 2015) (Transcript). The Court of Chancery also has withheld decision on multiple proposed settlements recently. See, e.g., In re Trulia, Inc. S\u2019holder Litig.<\/em>, C.A.\u00a0No. 10020-CB (Del. Ch. Sept. 16, 2015) (Transcript); In re Intermune, Inc. S\u2019holder Litig.<\/em>, Consol. C.A. No. 10086-VCN (Del. Ch. July 8, 2015) (Transcript).<\/p>\n

[6]<\/a> Acevedo<\/em>, Tr. at 65-67.<\/p>\n

[7]<\/a> See, e.g., Riverbed Tech.<\/em>, Mem. Op. at 14, 21 (awarding only $330,000 in attorneys\u2019 fees where $500,000 was requested by plaintiffs\u2019 counsel and not opposed by defendants); In re OpenTable, Inc. S\u2019holders Litig.<\/em>, Consol. C.A. No. 9776-CB (Del. Ch. May 27, 2015) (Transcript, p. 35) (awarding only $125,000 in attorneys\u2019 fees where $375,000 was requested by plaintiffs\u2019 counsel and not opposed by defendants); In re TW Telecom, Inc. S\u2019holders Litig.<\/em>, C.A. No. 9845-CB (Del. Ch. Aug. 20, 2015) (Transcript, p. 52) (awarding only $150,000 in attorneys\u2019 fees where $395,000 was requested by plaintiffs\u2019 counsel and not opposed by defendants).<\/p>\n

[8]<\/a> Riverbed Tech.<\/em>, Mem. Op. at 15 (emphasis added).<\/p>\n","protected":false},"excerpt":{"rendered":"

In recent years, the percentage of corporate mergers and acquisitions challenged through stockholder litigation has more than doubled. In 2007, 44% of deals valued over $100 million were the subject of stockholder lawsuits; by 2014, the number was 93%.[1] Merger litigation has become both reflexive and ubiquitous; plaintiffs\u2019 lawyers often file complaints on behalf of<\/p>\n","protected":false},"author":5,"featured_media":686,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[12,13],"tags":[102,103],"coauthors":[100,101],"class_list":["post-684","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-alumni-authored","category-business-law-practice","tag-delaware-court-of-chancery","tag-non-monetary-settlements","masonry-post","generate-columns","tablet-grid-50","mobile-grid-100","grid-parent","grid-33"],"yoast_head":"\nIncreased Judicial Scrutiny of Non-Monetary Settlements of Merger Litigation Threatens Business Model of Some Plaintiffs\u2019 Lawyers - The Temple 10-Q<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/law.temple.edu\/10q\/increased-judicial-scrutiny-of-non-monetary-settlements-of-merger-litigation-threatens-business-model-of-some-plaintiffs-lawyers\/\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Increased Judicial Scrutiny of Non-Monetary Settlements of Merger Litigation Threatens Business Model of Some Plaintiffs\u2019 Lawyers - The Temple 10-Q\" \/>\n<meta property=\"og:description\" content=\"In recent years, the percentage of corporate mergers and acquisitions challenged through stockholder litigation has more than doubled. 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