In 2014, the Delaware Supreme Court held in Kahn v. M&F Worldwide (MFW) that the business judgment rule applies to a transaction that would otherwise be subject to the exacting entire fairness standard of review due to the presence of a conflicted controlling stockholder so long as the parties condition the transaction at the outset (the "ab initio requirement") on approval by a fully empowered committee of disinterested and independent directors who comply with their duty of care (the "committee requirement") and approval by a majority of disinterested stockholders voting on a fully informed and uncoerced basis (the "majority-of-the-minority requirement"). At the time, practitioners generally lauded MFW as a welcome development that rebalanced the litigation risk landscape in a manner that enabled controlled companies to pursue a greater range of value-maximizing transactions. And in the decade that followed, many companies have taken advantage of the MFW framework to do just that.