Hauppauge Digital Inc v. James Rivest

Summary

The Supreme Court affirmed the Court of Chancery’s order requiring Hauppauge to produce historical financial statements under Section 220 without confidentiality restrictions. It held that confidentiality conditions are governed by a discretionary, context-specific balancing of the stockholder’s interest in communication against the corporation’s interest in confidentiality, without an evidentiary burden or presumption favoring either side. The court also held that Hauppauge’s alternative argument concerning Rivest’s access to the OTC Expert Market was waived and that the Vice Chancellor properly conducted de novo review of the recorded trial without holding a new trial.