The Delaware Chancery Court has denied a majority of the Section 220 requests that have been litigated before it during the past year. At first glance, it may appear as if the court is trying to discourage such requests, but several Delaware corporate attorneys insist that the court is not trying to send a message to shareholders.

Section 220 of the Delaware General Corporation Law allows shareholders to access the books and records of the corporations they own in order to investigate possible wrongdoing. A shareholder can make a request for the records under Section 220 provided they meet certain criteria including a proper purpose for requesting the records.

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