“Florida Adopts the In Re Trulia Standard for Disclosure-Based M&A Transaction Settlements”
Florida’s Second District Court of Appeal announced on July 13, 2018 the adoption of the review standard formulated in the Delaware Chancery Court opinion in In re Trulia, Inc. Stockholder Litigation, 129 A.3d 884 (Del. Ch. 2016) for class action disclosures-only settlements arising out of M&A transactions. This ruling is binding on Florida trial courts in all circuits. This Stroock Special Bulletin examines the Second District’s decision, which included the adoption of the clarifications of the In re Trulia standard provided by the U.S Seventh Circuit Court of Appeals in Hays v. Walgreen Co., 832 F.3d 718 (7th Cir. 2016).