A fee-shifting order in the Gilead Sciences Inc. case doesn’t change Delaware’s Section 220 law—which governs how and when corporate books and records must be subject to inspection—but it’s the latest Chancery Court pronouncement that is part of a gradual definition of hazy boundaries in a form of litigation that’s become increasingly prevalent.

Chancellor Kathaleen McCormick’s decision in July to require the Bay Area maker of an HIV drug to pay $1.7 million in shareholders’ attorney fees due to its “glaringly egregious” legal tactics is the first to hold a corporate defendant financially liable for the cost of Section 220 litigation and the latest of several in the past year that have fallen in shareholders’ favor and resulted in corporations being ordered to hand over books and records.