Tiger v. Boast Apparel, Inc.

Summary

The Supreme Court of Delaware held that a Section 220 inspection is not subject to a presumption of confidentiality, although the Court of Chancery may impose reasonable confidentiality conditions. Any confidentiality period must be determined by balancing the stockholder’s legitimate interests in communication against the corporation’s legitimate confidentiality interests, and the stockholder need not show exigent circumstances to obtain a period shorter than indefinite. Despite the Court of Chancery’s incorrect formulation, its order was reasonable under the circumstances and was affirmed.