The Delaware Court of Chancery, in Avande, Inc. v. Shawn Evans, et al., C.A. No. 2018-0203-AGB, memo. op. (Del. Ch. Aug. 13, 2019), found that defendants were not required to prove fairness of expenditures that plaintiff failed to make a prima facie showing were self-interested, but ordered an accounting for transactions plaintiff did show were self-interested.

K&L Gates discusses the decision in Chancery Orders Accounting For Payments to Former Director and CEO Affiliate; Rejects Most Breach of Fiduciary Duty Claims.