Investigative & Demand Committees Trusted Advisors

Investigative & Demand Committees

An extensive body of law has evolved regarding special committees, and Richards Layton has been at the forefront of this area of law from the start.  Our lawyers are skilled in addressing the legal, strategic and practical issues that frequently arise in special committee matters, including the formation of committees, the proper scope of the investigation, interviewing key persons, drafting reports, negotiating appropriate resolutions, and documenting the overall process.  We work to mitigate the risks that special committees face, ensure that committee members satisfy standards of director conduct, and help obtain the best outcome for the company.  We understand that many investigations require a practical approach and sensitivity to the companies’ ongoing operations, as well as other legal and financial considerations.  Richards Layton strongly believes in a bespoke approach to protecting its committee clients while helping to obtain the best result for the business.

Our firm has substantial experience representing special litigation committees formed to address matters involving stockholder derivative claims.  Indeed, in 1981 we represented the special litigation committee in the seminal case of Zapata Corp. v. Maldonado, the first case to recognize the availability of the special litigation committee procedure under Delaware law.  Since Zapata, we have acted extensively as counsel to special litigation committees, including those chartered to deal with derivative litigation involving corporations.

Since then, Richards Layton has frequently acted as counsel to special committees formed to investigate matters raised in stockholder demands, whistleblower complaints, and similar circumstances.  For example, we have frequently represented committees of the boards of directors of major corporations formed to consider issues such as alleged stock price manipulation, securities violations, breach of the duty of oversight, other alleged breaches of fiduciary duty, related party transactions, harassment, and many regulatory issues such as antitrust or insider trading issues.

We Wrote the Book on Special Committee Practice

Two of our directors wrote Special Committees: Law and Practice.  This comprehensive book gives practitioners a thorough working knowledge of special committee law, how to best utilize special committees, and the role of special committee members.  Special Committees: Law and Practice is an authoritative reference on this important area of law—and a testament to the depth of knowledge and practical experience that our firm brings to advising special committees.

Select Experience

  • Richards Layton represented a special litigation committee of the board of a biotechnology company in connection with its investigation regarding a purported stockholder’s demand that the company dismiss its suit against the stockholder. The demand alleged that the company’s suit was frivolous, demonstrated gross mismanagement by the board, and was a waste of company assets.  The committee ultimately decided to dismiss the claims after its investigation.
  • Richards Layton represented a special litigation committee of the board of a publicly traded technology and social media company in its investigation regarding securities cases filed in California district court, and related derivative actions filed in California state court and Delaware Chancery Court. The committee ultimately held that the settlements were appropriate and in the best interests of the company and its stockholders.  The settlements were then approved by the California state and federal courts, and the Delaware action was dismissed.
  • We represented a special committee of a technology company’s board in connection with its investigation of potential Delaware fiduciary claims related to alleged false and misleading public disclosures.
  • Richards Layton represented a special committee of a midwestern financial institution in connection with a purported whistleblower complaint relating to concerns regarding harassment, discrimination, retaliation, regulatory issues, antitrust laws, securities laws, corporate governance, and diversity, equity, and inclusion.
  • We represented the special committee of the board of a medical device company regarding its investigation of potential Caremark and other Delaware fiduciary duty claims concerning breaches of a deferred prosecution agreement.
  • Richards Layton was counsel to a special committee of the board of a global biopharmaceutical company in connection with its investigation of potential Delaware fiduciary claims relating to off-label drug marketing and promotion and False Claims Act claims.
  • Richards Layton represented independent directors of a cryptocurrency company investigating potential wrongdoing in financial practices involving users, including in connection with potential lending and insolvency.
  • We represented the audit committee of a publicly traded natural gas company in connection with an internal investigation regarding anonymous reports concerning potentially excessive travel expenses incurred by a senior company fiduciary.
  • Richards Layton represented a committee of the board of a publicly traded technology and social media company in connection with its evaluation of whether certain litigation settlements would improperly benefit company directors.
  • We represented a special committee of the board of a Fortune 500 company in connection with its investigation of potential Caremark claims relating to government antitrust investigations. We requested and received millions of pages of company documents, conducted over 30 interviews, and assessed the company’s procedures and controls regarding FCPA and antitrust compliance.
  • Richards Layton represented a special committee of a digital media company in connection with its investigation into purported wrongdoing by purportedly interested officers in connection with a strategic review.
  • Richards Layton represented a Fortune 500 company in connection with investigating allegations of sexual harassment and other inappropriate behavior by a key officer. We conducted a highly expedited investigation resulting in action taken against the officer.
  • We represented the custodian of a cryptocurrency company in connection with investigating various claims, including allegations brought in the Court of Chancery relating to fiduciary duties and other potential regulatory issues spanning the globe. A Richards Layton director served as the custodian of the entire cryptocurrency company.
  • Richards Layton was counsel to a special committee of the board of a sanitation company in connection with its investigation regarding alleged false and misleading statements concerning the company’s financial condition and internal controls.
  • We assisted a special committee of the board of a Fortune 500 company with its investigation regarding potential Virginia fiduciary claims related to alleged anti-competitive practices.
  • Richards Layton served as counsel to a special committee of the board of a Fortune 500 company in connection with its investigation of potential Virginia fiduciary claims and federal securities law violations regarding certain alleged public misstatements and omissions and purported insider trading.
  • Richards Layton was counsel to a special committee of the board of a Fortune 500 company to assist with its investigation of potential fiduciary duty claims relating to alleged antitrust violations.
  • We represented a special committee of the board of a Fortune 500 company in connection with its investigation of potential Virginia fiduciary claims and federal securities law claims relating to the hiring and employment of a top officer.
  • Richards Layton represented a publicly traded technology company in connection with its investigation of fiduciary claims regarding alleged false and misleading public disclosures and insider trading.
  • Richards Layton was counsel to a special committee of the board of a telecommunications company in connection with its investigation of potential Delaware fiduciary claims related to a business acquisition and alleged false and misleading disclosures.
  • We represented a special committee of the board of a publicly traded technology company to assist with its investigation of potential Delaware fiduciary claims concerning accounting errors that required the company to restate its financial statements.
  • Richards Layton was counsel to a special committee of the board of a sports media company in connection with its investigation of potential fiduciary claims regarding the board’s alleged failure to supervise or terminate for cause a senior executive officer who engaged in wrongdoing and misused company funds.
  • Richards Layton represented a special committee of the board of a biotechnology company in connection with its investigation regarding a purported stockholder’s demand that the company dismiss its suit against the stockholder. The demand alleged that the company’s suit was frivolous, demonstrated gross mismanagement by the board, and was a waste of company assets.
  • We were counsel to the audit committee of the board of a Fortune 500 company regarding its investigation of potential fiduciary claims in connection with alleged customer mistreatment, fraud, and other corporate wrongdoing that purportedly led the company to make false and misleading public disclosures regarding its business practices.
  • Richards Layton represented a special committee of the board of a publicly traded apparel company in connection with its investigation of potential fiduciary claims related to alleged sexual misconduct by a senior company executive, the board’s oversight of and response to the alleged misconduct, and the board’s review and approval of certain related-party transactions.
  • We assisted a special committee of the board of a Fortune 500 company with its investigation regarding alleged violations of state and federal law related to the company’s business practices and royalty payments, as well as potential Caremark claims against the company’s directors and officers. We reviewed the company’s internal investigation, conducted a supplemental investigation, and analyzed potential claims.
  • Richards Layton served as counsel to a special committee of the board of an oil and gas company and assisted with its investigation of potential Caremark claims regarding alleged violations of federal and state air-quality laws and regulations.
  • Richards Layton represented the special committee of the board of a publicly traded electronics company in connection with its investigation of potential Delaware fiduciary claims concerning company insider stock repurchases that were not disclosed as related-party transactions. We also represented the special committee in a derivative suit in which the plaintiff alleged that the special committee had wrongfully refused the plaintiff’s demand.  The plaintiff’s complaint was dismissed with prejudice.
  • We represented a special committee of the board of a Fortune 500 company with regard to its investigation of potential fiduciary claims and violations of the company’s federal securities disclosure and tax reporting obligations in connection with executives’ alleged personal use of the company aircraft.
  • Richards Layton assisted a special committee of the board of a publicly traded fashion company with its investigation of potential fiduciary claims in connection with the company’s decision to approve an amendment to a key employee’s employment agreement, as well as potential violations of the Sarbanes-Oxley Act regarding the company’s decision to modify and forgive a loan to the employee.
  • We were counsel to a special committee of the board of a petroleum products retailer in connection with its investigation of fiduciary duty claims governed by Maine law, including claims related to purportedly excessive executive compensation, company investment decisions, and a potential company sale.
  • Richards Layton represented a special committee of the board of a publicly traded battery technology company in connection with its investigation of potential fiduciary duty claims related to an allegedly defective vote concerning a charter amendment to extend the SPAC’s termination date. We filed a Section 205 petition to validate an amendment to the SPAC’s charter that extended the SPAC’s termination date, a subsequent de-SPAC merger, an associated de-SPAC charter, and an issuance of common stock following the de-SPAC merger.
  • We represented a special litigation committee of the board of a publicly traded telecommunications company in connection with its investigation of fiduciary duty claims related to the board’s decision to vote in favor of a merger transaction that caused director-owned stock options to vest.