In Clem v. Skinner, the Delaware Court of Chancery dismissed yet another Caremark suit, once again showing that a Caremark claim remains "possibly the most difficult theory in corporation law upon which a plaintiff might hope to win a judgment." "Fueled by hindsight bias," Vice Chancellor Lori W. Will explained, Caremark suits have "proliferated in Delaware" seeking to hold directors personally liable for imperfect efforts, operational struggles and business decisions. But, the court noted, a stockholder's position that the board's response to a corporate crisis merely "came too late and did too little" is insufficient under Caremark, which requires a showing that directors acted in bad faith.