In In re Wal-Mart Stores Delaware Derivative Litigation
, C.A. No. 7455-CB (Del. Ch. May 13, 2016), the Delaware
Court of Chancery held that an order of the U.S. District Court for the Western District of Arkansas dismissing an
Arkansas complaint precluded Delaware plaintiffs from litigating demand futility in a Delaware derivative action
challenging the same underlying conduct. Although the Court of Chancery's opinion primarily involves an analysis of
the requirements for issue preclusion under Arkansas law, it also provides important guidance on multiforum
litigation for Delaware corporations and practitioners.