Post-Demand Evidence and Anonymous Sources in Delaware Section 220 Inspection Actions: The Delaware Supreme Court’s 3–2 Decision in Paramount Global

On March 25, 2026, the Delaware Supreme Court issued a significant and closely divided opinion in Paramount Global v. State of Rhode Island Office of the General Treasurer, addressing two unsettled questions in stockholder books-and-records litigation under Section 220 of the Delaware General Corporation Law (DGCL).By a 3–2 vote, the court affirmed the Court of Chancery’s ruling that post-demand evidence may, under appropriate circumstances, be used to establish the “proper purpose” required for... By: ALTO Litigation