In Re Appraisal of PetSmart, Inc.

CourtCourt of Chancery of Delaware
DecidedMay 26, 2017
DocketCA 10782-VCS
StatusPublished

This text of In Re Appraisal of PetSmart, Inc. (In Re Appraisal of PetSmart, Inc.) is published on Counsel Stack Legal Research, covering Court of Chancery of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re Appraisal of PetSmart, Inc., (Del. Ct. App. 2017).

Opinion

EFiled: May 26 2017 11:52AM EDT Transaction ID 60650885 Case No. 10782-VCS

IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE

: IN RE APPRAISAL OF PETSMART, INC. : CONSOLIDATED : C.A. No. 10782-VCS

MEMORANDUM OPINION

Date Submitted: February 27, 2017 Date Decided: May 26, 2017

Stuart M. Grant, Esquire, Nathan A. Cook, Esquire, Kimberly A. Evans, Esquire, and Joseph L. Christensen, Esquire of Grant & Eisenhofer P.A., Wilmington, Delaware, Attorneys for Petitioners.

Gregory P. Williams, Esquire, Brock E. Czeschin, Esquire, John D. Hendershot, Esquire, Robert L. Burns, Esquire, Sarah A. Clark, Esquire, and Matthew D. Perri, Esquire of Richards, Layton & Finger, P.A., Wilmington, Delaware, and Theodore N. Mirvis, Esquire, Rachelle Silverberg, Esquire, Adam M. Gogolak, Esquire, Adam D. Gold, Esquire, and Joshua J. Card, Esquire of Wachtell, Lipton, Rosen & Katz, New York, New York, Attorneys for Respondent PetSmart, Inc.

SLIGHTS, Vice Chancellor I would not be the first to observe that the trial of an appraisal case under the

Delaware General Corporation Law presents unique challenges to the judicial

factfinder.1 The petitioner bears a burden of proving the “fair value” of his shares;

the respondent bears a burden of proving the “fair value” of the petitioner’s shares;

and then the judge, as factfinder, assumes, in effect, a third burden to assign a

particular value “as the most reasonable [] in light of all of the relevant evidence and

based on considerations of fairness.”2 The role assigned to the trial judge in this

process independently to review “all relevant factors” that may inform the

determination of fair value, if not unique, is certainly unusual.3 It is unusual in the

sense that the judge is not bound by the positions on fair value espoused by either of

1 See In re Appraisal of Ancestry.com, Inc., 2015 WL 399726, at *2 (Del. Ch. Jan. 30, 2015); Albert H. Choi & Eric L. Talley, Appraising the “Merger Price” Appraisal Rule (Virginia Law and Economics, Working Paper No. 2017-01, Jan. 18, 2017). 2 Cede & Co. v. Technicolor, Inc., 2003 WL 23700218, at *2 (Del. Ch. July 9, 2004), aff’d in part, rev’d on other grounds, 884 A.2d 26 (Del. 2005). 3 8 Del. C. § 262(h). See Ancestry.com, 2015 WL 399726, at *1 (noting that the burdens of proof imposed by Section 262 makes the job of the judge “particularly difficult” and that the litigation structure imposed by the statute is “unusual”); Choi & Eric Talley, supra, at 2 (noting that the appraisal statute presents a “particularly vexing challenge” for the trial judge, inter alia, because it “allocates no explicit burden of proof and requires the court to deliver a single number at the end of the process”) (emphasis in original).

1 the parties. Indeed, the trial court commits error if it simply chooses one party’s

position over the other without first assessing the relevant factors on its own.4

Yet it cannot be overlooked that the judge’s decision in an appraisal case

follows a trial––an honest-to-goodness, adversarial trial––where the parties are

incented to present their best case, grounded in competent evidence, and to subject

their adversary’s evidence to the discerning filter of cross-examination. The trial

court then reviews the evidence the parties have placed in the trial record and does

its best to “distill the truth.”5 In this regard, at least, the appraisal trial is no different

from any other trial. The court’s determination of “fair value,” while based on “all

relevant factors,” must still be tethered to the evidence presented at trial. The

appraisal statute is not a license for judicial freestyling beyond the trial record.

This appraisal action follows a going-private merger in which the public

stockholders of PetSmart, Inc. (“PetSmart,” the “Company” or the “Respondent”)

received $83 per share in cash from a private equity acquiror, BC Partners, Inc. (the

“Merger”). The Merger closed on March 11, 2015. Petitioners declined the Merger

consideration and demanded appraisal.

4 See Gonsalves v. Straight Arrow Publ’rs, Inc., 701 A.2d 357, 362 (Del. 1997) (holding that the trial court’s decision to adopt one of the parties’ valuations of the company “hook- line-and-sinker” without considering all relevant factors was “fatally flawed”). 5 See Finkelstein v. Liberty Digital, Inc., 2005 WL 1074364, at *24 n.56 (Del. Ch. Apr. 25, 2005).

2 The battle lines staked here rest on positions that are well-known to Delaware

courts, the academy and those who otherwise follow the evolving state of Delaware

appraisal litigation. The Respondent would have me determine fair value by

deferring to the price paid by a third-party purchaser in an arm’s-length transaction

after an allegedly robust pre-signing auction process. The Petitioners insist that

“deal price” is unreliable in this case for a variety of reasons and urge me to

determine fair value by employing a tried and true valuation methodology,

discounted cash flow (“DCF”). The experts engaged by the parties, both well

credentialed, sponsor these differing views with unwavering commitment. Indeed,

the parties are so certain of their respective positions on the fair value of PetSmart

at the time of the Merger that they insist I disregard the other’s proffered

methodology entirely. The result: Respondent values PetSmart at $83 per share;

Petitioners value the same firm at $128.78 per share.

In this post-trial opinion, I conclude that the evidence presented during trial

points in only one direction––Petitioners have failed to carry their burden of

persuasion that a DCF analysis provides a reliable measure of fair value in this case.

The management projections upon which Petitioners rely as the bedrock for their

DCF analysis are, at best, fanciful and I find no basis in the evidence to conclude

that a DCF analysis based on other projections of expected cash flows would yield

a result more reliable than the Merger consideration. Nor is there a foundation in

3 the evidence for concluding that some other valuation methodology might lead to a

reliable determination of fair value. On the other hand, I am satisfied Respondent

has carried its burden of demonstrating that the process leading to the Merger was

reasonably designed and properly implemented to attain the fair value of the

Company. Moreover, the evidence does not reveal any confounding factors that

would have caused the massive market failure, to the tune of $4.5 billion (a 45%

discrepancy), that Petitioners allege occurred here. Based on my review of all

relevant factors, as found in the evidence, I am satisfied that the deal price of $83

per share, “forged in the crucible of objective market reality,”6 is the best indicator

of the fair value of PetSmart as of the closing of the Merger.7

I. BACKGROUND

I recite the facts as I find them by a preponderance of the evidence after a

four-day trial beginning in October 2016. That evidence consisted of testimony from

seventeen witnesses (thirteen fact witnesses, some presented live and some by

deposition, and four live expert witnesses) along with over 2300 exhibits. To the

6 Van de Walle v. Unimation, Inc., 1991 WL 29303, at *17 (Del. Ch. Mar. 7, 1991).

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