Roberta Ann K.W. Wong Leung Revocable Trust U/A Dated 03/09/2018 v. Amazon.com, Inc.

Summary

The Supreme Court of Delaware reversed the Court of Chancery's denial of a stockholder's Section 220 inspection demand. The court held that the demand's purpose was not facially improper or impermissibly broad and that the lower court was required to evaluate the evidence rather than end its analysis at the scope stage. The court further held that the combined evidence of government investigations, lawsuits, a consent decree, and a substantial foreign fine established a credible basis to infer possible wrongdoing. The case was remanded to determine the scope and conditions of production.