For decades, Delaware's legal framework for stockholder derivative claims targeted at corporate oversight—colloquially referred to as Caremark claims—was well-established. Caremark claims, which challenge failures to act rather than affirmative actions, could be brought against a company's board of directors, but the bar for liability was high. For over 20 years prior to 2019, no such claims survived a motion to dismiss, reinforcing then-Chancellor William Allen's statement in Caremark itself that such a theory is "possibly the most difficult theory in corporation law upon which a plaintiff might hope to win a judgment."