Fir Tree Value Master Fund v. Jarden Corp

Summary

The Court affirmed the appraisal award valuing Jarden shares at $48.31, holding that unaffected market price may constitute the best evidence of fair value when supported by the record and accepted financial principles. The Court also held that the merger price was not a valuation floor because the sale process was flawed and the price likely included synergies, and that the Court of Chancery acted within its discretion in declining to rely primarily on the parties’ divergent discounted cash flow models. The Court found no abuse of discretion in the lower court’s use and later correction of its terminal investment rate.