Sheldon v. Pinto Technology Ventures, L.P.

Summary

The Supreme Court of Delaware affirmed dismissal with prejudice of shareholders' dilution claims against venture capital firms and directors of IDEV Technologies. The court held that the complaint did not reasonably conceiveably allege that the venture capital firms were connected by a legally significant agreement or arrangement sufficient to constitute a control group, so the claims were solely derivative and the plaintiffs lacked standing after IDEV's acquisition. The court therefore did not reach other possible grounds for dismissal.