Shareholders can’t use an appraisal action in Delaware Chancery Court as a substitute for a books-and-records demand in hopes it will garner more extensive discovery, Chancellor Kathaleen McCormick has decided.

A Monday opinion in an appraisal case filed by shareholders of Zoox Inc., an autonomous vehicle developer Amazon agreed to purchase for $1.3 billion in 2020, concludes allowing broader discovery for an appraisal would counteract Delaware’s push in recent years toward Section 220 litigation as a means for shareholders to investigate potential corporate wrongdoing.

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