Monthly Archives: August 2025

Delaware Court Dismisses Claims Against Directors for Failing to Investigate Past Misconduct

Heather Benzmiller Sultanian is a Partner at Sidley Austin LLP. This post is based on her Sidley memorandum, and is part of the Delaware law series; links to other posts in the series are available here.

In a recent dismissal of all claims in Borsody v. Gibson, the Delaware Court of Chancery grappled with an unusual set of circumstances involving a former director who believed he had been wrongfully removed from a board and prevented from exercising his stock options. Having missed the window for asserting claims against the two officers who allegedly engaged in the wrongful scheme, he instead targeted two new directors who did not join the Board until after the scheme had already been completed.

Plaintiff Mark Borsody co-founded and chaired the Board of a medical device company, Nervive, Inc. The complaint alleged that, in late 2019, Borsody was denied contractually-owed stock options (which had been granted through a Stock Option Agreement) and ousted from the Board after he began to question the interim CEO’s dealings with potential investors. Shortly thereafter, in October 2019, two new directors were appointed to the Board, one of whom had previously served as CEO of Nervive and allegedly felt “personal animus” toward Borsody. The following month, Borsody attempted to exercise his stock options, but Nervive refused to recognize the exercise — despite advice from Nervive’s counsel that Borsody’s claims to the stock options were legitimate.

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Shareholder Proposal Developments During The 2025 Proxy Season

Elizabeth A. IsingRonald O. Mueller, and Geoffrey Walter are Partners at Gibson Dunn. This post was prepared for the Forum by Ms. Ising, Mr. Mueller, Mr. Walter, Natalie Abshez, Meghan Sherley, and Sherri Starr.

This post provides an overview of shareholder proposals submitted to public companies during the 2025 proxy season, including statistics and notable decisions from the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) on no-action requests. As discussed below, based on the results of the 2025 proxy season, there are several key takeaways to consider for the coming year:

  • Shareholder proposal submissions fell for the first time since 2020.
  • The number of proposals decreased across all categories (social, governance, environmental, civic engagement and executive compensation).
  • No-action request volumes continued to rise and outcomes continued to revert to pre-2022 norms, with the number of no-action requests increasing significantly and success rates holding steady with 2024.
  • Anti-ESG proposals continued to proliferate in 2025, but shareholder support remained low.
  • Data from the 2025 season suggests that the Staff’s responses to arguments challenging politicized proposals (those proposals that express either critical or supportive views on ESG, DEI and other topics) were driven by the specific terms of the proposals and not by political perspectives.
  • New Staff guidance marked a more traditional application of Rule 14a-8, but the results of the 2025 season indicate that Staff Legal Bulletin 14M (“SLB 14M”) did not provide companies with a blank check to exclude proposals under the economic relevance, ordinary business or micromanagement exceptions.

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Overlapping Directors as a Competition Problem

Mark A. Lemley is the William H. Neukom Professor of Law at Stanford Law School, and Rory Van Loo is a Professor of Law at Boston University School of Law. This post is based on a recent paper by Professor Lemley, Professor Van Loo, and Lane Miles.

Antitrust law prohibits competing corporations from sharing board members—called “interlocking directorates”—and has for more than a century. Violating it is one of the few things antitrust declares illegal per se, with no opportunity to explain or justify the interlock. Yet our new empirical evidence suggests that the rule is routinely broken. Using proprietary data, we contribute a comprehensive assessment of interlocks in both public and private firms, finding over two thousand instances of individuals sitting on the boards of two companies that are direct competitors. Among companies where we know at least five directors, 8.1 percent (2,309) had an individual interlock.

But the same individual sitting on two competing boards, despite being the focus of the interlock literature and most of the case law, isn’t the only problem. We also demonstrate the prevalence across public and private companies of a related problem—two different individuals sitting on competitors’ boards while simultaneously working at the same private equity, venture capital, or other firm that also invests in the competitors on whose boards the director sits. These investment funds can thereby influence boards through a hidden mechanism—installing two of their employees on competitors’ boards. Such investor-level interlocks are even more common than individual interlocks, reaching 2,927 different companies and 9.9 percent of the companies with at least five board members in our data set. Yet their prevalence was until now unknown.

Combined, individual and investor-level interlocks reach 13.4 percent of all companies—including 30.1 percent of life-sciences companies and 18.9 percent of all IT and software companies. Moreover, in 56.8 percent of the investor-level interlocks the investor invested in both of them. Consequently, the two board members share an institutional identity that creates strong financial incentives for the competing companies to collude and the organizational touchpoints and close relationships to make it happen.

Our data on fund employment also enables us to shed light on the identity of the individual interlocking directors. About 65 percent of those we identified hold leadership positions in private-equity, venture-capital, and other investment funds that invest in the very companies on whose boards these directors sit. The interlocking directors are often partners of investment firms, which means they receive a share of the fund’s investment profits, giving them additional personal financial incentives to promote anticompetitive conduct. READ MORE »

Weekly Roundup: August 22-28, 2025


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This roundup contains a collection of the posts published on the Forum during the week of August 22-28, 2025

Reinforcing Ethics and Oversight in Corporate Governance: Essentials for Public Companies


Wildest Campaigns 2025


A Decade Later, the Corwin Doctrine Still Packs a Knockout Punch




Are Institutional Investor Preferences for Performance-Based Equity Really Diminishing in Favor of Time-Based Shares?


Chancery Decision Doubles Down on Due Diligence


2025 Proxy Season in Review


Are CEO Pay Plans Too Samey?


The “Big Three” Shift Approach to Stewardship


Why Corporate Directors Must Keep Their Company’s Long-Term Mission in Focus


How Boards Can Prepare for Increasing Nation-State Cyber Threats


How Boards Can Prepare for Increasing Nation-State Cyber Threats

Mike Driscoll is a Senior Managing Director, and Sara Sendek is a Managing Director at FTI Consulting. This post is based on their FTI Consulting memorandum.

Rising geopolitical tensions are likely to lead to an increase in cyber threats from nation-states. Boards have a great responsibility to ensure resilience beyond compliance.

As a growing number of governments around the world pull away from globalization, diplomatic and economic ties risk weakening. This could lead to nation-states feeling emboldened to carry out cyber attacks with less concern for damaging relationships that are already deteriorating and, in turn, could pose widespread risks for organizations.

A new report from FTI Consulting, Corporate Board Member and Diligent Institute found that while 79 percent of board members whose companies have international exposure beyond the United States view geopolitical risks as a threat to their business strategy, less than ten percent are prioritizing the management of geopolitical risks.

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Why Corporate Directors Must Keep Their Company’s Long-Term Mission in Focus

Jon Solorzano, Sebastian Tiller, and Francisco Morales Barron are Partners at Vinson & Elkins LLP. This post is based on their Vinson & Elkins memorandum.

Corporate boards are no stranger to near-term pressures, but these days the pressures are piling as high as they ever have. Geopolitical tensions and supply-chain disruptions; climate change and technological revolutions; tariff uncertainty, cyberthreats, regulatory upheaval, and more. Each creates risks for companies across industries and market capitalizations. And in keeping with directors’ fiduciary duties, they all demand board time, energy, and focus.

Amid these pressures and others, thinking long term — that is, defining a sound strategic vision and executing on it — has become increasingly difficult and, at times, may seem at odds with near-term business demands. Complicating matters further, this dynamic is playing out at a time when thinking long term is increasingly critical for a company’s success, yet may seem out of favor with the current corporate zeitgeist.

Yes, boards need to stay mindful of near-term trends in business, technology, politics, and the like — and consider them in their oversight of the company on behalf of its shareholders. But boards who center corporate agendas entirely on issues facing the company in the here and now risk setting their company up to underperform in the coming years.

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The “Big Three” Shift Approach to Stewardship

David A. Katz and Elina Tetelbaum are Partners, and Loren Braswell is Counsel at Wachtell Lipton Rosen & Katz. This post is based on their Wachtell Lipton memorandum.

Robust shareholder engagement continues to be a critical component of corporate governance, as well as a key element of shareholder activism preparedness. Proactively maintaining a dialogue with the company’s largest shareholders allows the company to establish credibility, lay out its strategy and address concerns before they escalate. A fundamental part of this effort is understanding the company’s unique shareholder base—who the key shareholders are, what their voting policies and priorities look like and how they have historically voted or engaged on specific issues. This information allows companies to anticipate potential concerns and tailor their strategies and communications accordingly. Understanding the company’s specific shareholder base is especially important in the context of activist approaches and potential proxy fights, as voting outcomes can sometimes be determined by razor-thin margins, hinging on the votes of just one or a handful of influential investors.

This critical task has recently become more complex, as the “Big Three” asset managers—BlackRock, Vanguard and State Street—are shifting their approach to stewardship. In particular, each of the “Big Three” is splitting its proxy voting team into two separate groups, each with their own voting decision-makers, voting policies and perspectives.

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Are CEO Pay Plans Too Samey?

Will Arnot is Deputy Newswire Editor at Diligent Market Intelligence (DMI). This post is based on a Diligent memorandum by Mr. Arnot, Josh Black, and Antoinette Giblin.

CEO pay in the S&P 500 has continued to record substantial gains with only a marginal drop-off in investor support, writes Will Arnot.

With the stock market up again in 2024, median CEO compensation in the S&P 500 saw an 8% year-on-year increase while also managing to maintain steady support from investors.

According to DMI Compensation data, the median granted pay for an S&P 500 CEO was $17.2 million in 2024, up from a median of $15.9 million median package awarded for 2023.

This 8.3% increase may have been considered good value considering the S&P 500 delivered an average total shareholder return of 25% in 2024, following a 24% gain in 2023.

Indeed, the average S&P 500 “say on pay” proposal received 89.3% support in the first half of this year, down only marginally on the 89.4% support similar proposals received in the same timeframe last year with experts citing pay plan design practices and regulatory changes as potential factors. Four “say on pay” resolutions failed in the first half of 2025, down from five last year.

Nine S&P 500 companies faced between 40% and 49% opposition to their executive compensation proposals in H1, including Chipotle Mexican Grill and Pfizer while the same period in 2024 saw eight companies face similar levels of opposition.

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2025 Proxy Season in Review

Simone Hicks, Benjamin R. Pedersen, and Paul Rodel are Partners at Debevoise & Plimpton LLP. This post is based on a Debevoise memorandum by Mr. Hicks, Mr. Pedersen, Mr. Rodel, Eric Juergens, Alison Buckley-Serfass, and Amy Pereira.

Key Takeaways:

  • The 2025 proxy season was an eventful one—unfolding against the backdrop of a new federal administration, changes to the regulatory landscape, and evolving investor sentiment on a variety of issues.
  • Based on our experience and data compiled by Diligent, this Debevoise In Depth identifies key takeaways from the 2025 proxy season.

The 2025 proxy season was an eventful one—unfolding against the backdrop of a new federal administration, changes to the regulatory landscape, and evolving investor sentiment on a variety of issues. New guidance from the U.S. Securities and Exchange Commission relating to Schedule 13G eligibility and no-action relief had immediate impacts on shareholder engagement, while revised proxy advisor and institutional shareholder guidelines were cause for many companies to review their DEI initiatives and related disclosures. As in prior years, investors demonstrated willingness to hold directors accountable, through traditional proxy contests as well as through “withhold” campaigns.

 

Based on our experience and data compiled by Diligent, this Debevoise In Depth identifies key takeaways from the 2025 proxy season.

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Chancery Decision Doubles Down on Due Diligence

Gail Weinstein is a Senior Counsel, Philip Richter is a Partner, and Steven Epstein is the Managing Partner at Fried, Frank, Harris, Shriver & Jacobson LLP. This post is based on a Fried Frank memorandum by Ms. Weinstein, Mr. Richter, Mr. Epstein, Steven J. Steinman, Randi Lally, Mark Lucas, and is part of the Delaware law series; links to other posts in the series are available here.

In Edwards v. GigaAcquistions2, LLC (July 25, 2025), the Delaware Court of Chancery dismissed a case, at the pleading stage, in which former members of Cloudbreak Health, LLC, a high-performing health care company, claimed that Cloudbreak was fraudulently induced to join in a de-SPAC combination with a group of financially distressed health care companies (the “Portfolio Companies”). The combined company went bankrupt post-closing. Cloudbreak had received oral assurances and management presentations indicating that the Portfolio Companies were financially sound and positioned for success. A few years after the closing, it came to light that the information about the Portfolio Companies’ financial wellbeing, that had been provided by the Portfolio Companies, their financial advisor and the SPAC sponsor, was false. The court dismissed the plaintiffs’ claims on several grounds—most notably, refusing to toll the statute of limitations for fraud, which had lapsed shortly before the suit was filed.

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