The Delaware Court of Chancery on Feb. 23 said AOL Inc.’s $4.4 billion sale to Verizon Communications Inc. overvalued the once-powerful media technology company by more than $1.30 per share, in another blow to holdout shareholders looking to exercise their appraisal rights in Delaware.

The ruling, from Vice Chancellor Sam Glasscock III, was the second this month to find the fair value below the deal price in light of two recent decisions by the state Supreme Court. However, both reflected the differences in reasoning and valuation methods that judges employ at a time when the very nature of appraisal in Delaware is in flux.

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