Delaware high court endorses deal price for fair value in appraisal actions

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Abstract: In a landmark decision, the Delaware Supreme Court has made clear its preference for valuations based on the deal price in appraisal proceedings. This article summarizes the case, which concludes that “the collective judgment of many” is generally considered superior to other valuation models imposed by a single analyst. A sidebar highlights a subsequent statutory appraisal case that was remanded to the Chancery Court on similar grounds. DFC Global Corp. v. Muirfield Value Partners, L.P., No. 518, 2016, 172 A.3d 346, Supreme Court of Delaware, August 1, 2017 Dell, Inc. v. Magnetar Global Event Driven Master Fund Ltd., No. 565, 2016, 177 A.3d 1, Supreme Court of Delaware, December 14, 2017