In a December decision, Delaware Chancery Court Vice Chancellor J. Travis Laster crafted a formula for evaluating attorney fees in shareholder suits where the plaintiffs successfully challenge a transaction’s deal protection measures but receive no monetary reward.

Laster developed the formula inIn re Compellent Technologies Inc. Shareholder Litigation , awarding $2.4 million in fees and expenses to plaintiffs’ attorneys. The plaintiffs’ attorneys originally requested $6 million, while the defendants argued that the attorneys should not be awarded more than $1.25 million.

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