Henry T. C. Hu is the Allan Shivers Chair in the Law of Banking and Finance at the University of Texas Law School. This paper is based on his recent article, forthcoming in the Journal of Corporation Law.
Strategy Inc (MSTR), formerly MicroStrategy Incorporated, functions differently from other public companies. At its core, the firm produces no goods or services, has no operating cash flow, and does not compete with other companies. Yet, by early 2025, its share price had risen 27-fold since it began its transformation to a new corporate model less than five years earlier. Its stock’s 110% annualized return was multiples higher than any S&P 500 stock. In a Financial Times film released that spring, Michael Saylor, its chairman and co-founder, stated that the firm’s stock market capitalization of $100 billion “can grow” 100-fold to $10 trillion by 2045—i.e., the current combined market capitalization of Amazon, Apple, and Microsoft.
MSTR styles itself as the first and largest “bitcoin treasury company” (BTCo). Corporations worldwide began imitating its BTCo model. With 4% of all outstanding bitcoins, MSTR is the largest known institutional holder. In 2025 it issued more equity capital than any other U.S. company.
This Article is the first academic work on the law and economics of the MSTR model. It introduces two concepts: “corporate omphaloskepsis,” which helps capture the model’s ends and means, and “polypharmacy of financial risk,” which frames some key consequences for shareholders. MSTR’s path to shareholder wealth maximization departs from longstanding financial and legal understandings. For ordinary public companies, the animating engine of shareholder wealth management rests on the production of goods and services. Perhaps the foremost task of management is to produce new or better goods and services or ones at lower cost than competitors. The overarching pecuniary corporate end is to maximize the fundamental value of its shares, relying on a convergence of share price to fundamental value to maximize shareholder wealth. READ MORE
