The award of interest is one of those questions that decides real money but rarely receives sustained judicial attention. A recent decision from the Court of Chancery is a useful reminder that, in equity, the rate of interest is a
Carl D. Neff
Carl D. Neff is a Delaware licensed attorney with the law firm of Pierson Ferdinand LLP and is based in Delaware. Carl’s practice focuses in the areas of corporate and commercial litigation before the Delaware Court of Chancery, the Delaware Supreme Court, the Delaware Superior Court and the District of Delaware.
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Chancery Imposes Spoliation Sanctions Over Vanishing Signal Messages in the WWE Merger Litigation
By Carl D. Neff
The Court of Chancery has issued a significant decision on the preservation of electronically stored information, and it should give pause to anyone who relies on disappearing-message applications after litigation is on the horizon. In In re World Wrestling Entertainment…
Chancery Dismisses KnowBe4 Stockholder Challenge: No Control Group, and a Cleansing Vote
By Carl D. Neff
A recurring question in deal litigation is when a handful of large investors who roll over their equity in a take-private become a “control group” subject to entire fairness review. In Le Clair v. KnowBe4, Inc., C.A. No. 2024-1143-KSJM (Del.
When a Board Designee Serves Two Masters: Zync v. Porsche in the Court of Chancery
By Carl D. Neff
A recurring tension in venture-backed companies is that the investor who funds the business often wants a seat at the board table, and once its designee takes that seat, he or she owes fiduciary duties to the company, not to…
First Detailed RVO Opinion in the Second Circuit: In re Iovate Health Sciences International Inc.
By Carl D. Neff
On May 12, 2026, Chief Judge Martin Glenn of the United States Bankruptcy Court for the Southern District of New York issued a 27-page memorandum opinion in In re Iovate Health Sciences International Inc., Case No. 25-11958 (MG), recognizing and…
Does “Defend” Mean “Advance”? Not Necessarily, Says the Court of Chancery
By Carl D. Neff
A recent Court of Chancery decision underscores how much weight LLC drafters place on a single word, and how exposed a member can be when that word does not say what it needs to say. In USAB NY Inc. v.
No Authority, No Deadlock: Vice Chancellor Laster Dismisses LLC Dissolution Petition in Dynamk
By Carl D. Neff
Vice Chancellor J. Travis Laster’s recent opinion in In re: Dynamk Fund Advisors LLC, C.A. No. 2026-0002-JTL (Del. Ch. May 20, 2026) sits at the intersection of LLC dissolution claims, arbitration awards, and antisuit provisions. The court granted the respondent’s…
Calculation or Interpretation? Delaware Superior Court Holds Earn-Out Definition Dispute Falls Outside Accountant True-Up Mechanism
By Carl D. Neff
On April 24, 2026, the Complex Commercial Litigation Division of the Delaware Superior Court denied the buyer’s motion to dismiss in Second Run, LLC f/k/a Webata, LLC v. 1WorldSync, Inc., C.A. No. N25C-08-068 KMM CCLD (Del. Super. Apr. 24, 2026)…
Cumulus Media: Judge Pérez Confirms Prepackaged Plan Over U.S. Trustee’s Opt-Out Release Objection
By Carl D. Neff
On April 15, 2026, Judge Alfredo R. Pérez of the United States Bankruptcy Court for the Southern District of Texas confirmed the modified joint prepackaged Chapter 11 plan of Cumulus Media Inc. and its debtor affiliates at the conclusion of…
“A Product of Mutual Deceit”: Court of Chancery Rejects Manufactured Corporate Records in Section 225 Control Fight
By Carl D. Neff
In a case the court itself characterized as “a product of mutual deceit,” Vice Chancellor Will issued a post-trial memorandum opinion in Ami Shafrir Berg v. Shai Bar-Lavi, et al., C.A. No. 2025-0959-LWW (Del. Ch. Mar. 27, 2026), rejecting…