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In a recent opinion, the Delaware Supreme Court (the Court)
eased the burden on stockholders of Delaware corporations seeking
access to a corporation s books and records under Section 220
of the Delaware General Corporation Law (DGCL).
In
AmerisourceBergen Corporation v. Lebanon County
Employees Retirement Fund, 243 A.3d 417 (2020), the
Delaware Supreme Court affirmed a Delaware Court of Chancery
decision holding that (1) to state a proper purpose under Section
220, the plaintiff need not identify the particular course of
action the stockholder will take with the information gathered if