The Delaware Supreme Court, in Jeffrey J. Sheldon, et al. v. Pinto Technology Ventures, LP, et al., No. 81, 2019, opinion (Del. Oct. 4, 2019), affirmed the Court of Chancery’s dismissal of stockholders’ claims challenging a dilutive transaction supported by an alleged control group of venture capital investors, finding a voting agreement did not apply to the challenged transaction did not establish a “legally sufficient connection” between the venture capital investors.

Morris James discusses the decision in Delaware Supreme Court Provides Additional Guidance on Pleading Direct Claims Against Controllers and Control Groups.