Francis Pileggi discusses recent decisions of the Delaware Court of Chancery in books and records actions, contrasting Michael J. Donnelly v. Keryx Biopharmaceuticals, Inc., C.A. No. 2018-0892-SG, memo. op. (Del. Ch. Oct. 24, 2019), which granted inspection, with High River Limited Partnership, et al. v. Occidental Petroleum Corp., C.A. No. 2019-0403-JRS, memo. op. (Del. Ch. Nov. 14, 2019), which found requested records were not necessary and essential for use in a proxy contest, and Southeastern Pennsylvania Transportation Authority, et al. v. Facebook, Inc., C.A. No. 2019-0228-JRS, memo. op. (Del. Ch. Oct. 29, 2019), which found requested records were not necessary and essential to investigate an issue not considered by directors when setting executive compensation, in Chancery Grants a Section 220 Demand in One Case–Denies it in Two Others.