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In mid-March, the Delaware Supreme Court issued what is being described as a landmark ruling in the case Kahn v. M&F Worldwide Corp., which involved a shareholder challenge to the buyout of M&F by its controlling shareholder — MacAndrews & Forbes Holdings, Inc., an investment vehicle owned by Ronald Perelman. The court affirmed then-Chancellor Leo Strine’s use of the more deferential “business judgment” standard of review in granting a motion for summary judgment filed by the controlling shareholder. Until this decision, Delaware courts had typically applied the more stringent “entire fairness” standard in such cases.