The Court of Appeals recently handed down a significant decision in Eccles, et al. v. Shamrock Capital Advisers, et al., which clarified the choice-of-law principles governing alleged breaches of fiduciary duties in international business disputes. The case centered on the merger of FanDuel Ltd. (FanDuel), a company incorporated in Scotland, with the U.S. assets of Paddy Power Betfair PLC (Paddy Power), and it questioned whether Scottish law or New York law should govern the fiduciary duty claims that arose from the merger.