Security First Corp. v. U.S. Die Casting & Development Co.

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that, to institute a proper § 220 action to investigate fraud, the plaintiff must demonstrate “a credible basis to find probable wrongdoing”
• holding that Section 220 is not a vehicle from which to launch a fishing expedition
• holding that a Section 220 plaintiff must demonstrate that each category of books and records requested is “essential to the accomplishment of the stockholder’s articulated purpose for the inspection”
• holding that while the plaintiff “need not actually prove the wrongdoing itself by a preponderance of the evidence,” he must show “a credible basis from which the Court of Chancery can infer there is possible mismanagement that would warrant further investigation.”
• noting that “[t]his Court reviews de novo the question of a ‘proper purpose’ under Section 220(b)”
• noting that Section 220 actions “are not the same and should not be confused” with Rule 34 discovery requests

Source: CourtListener parenthetical corpus (CC0).