Inclusion on a company’s stock ledger, by itself, does not give a plaintiff standing to sue for books-and-records access, the Court of Chancery ruled last week.
In an 11-page memorandum opinion, Vice Chancellor Sam Glasscock III said such a listing creates a prima facie, but rebuttable, case that a plaintiff is a stockholder of record. Companies, he said, can combat the presumption with “clear and convincing” evidence beyond the corporate document.
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