In Re: Emisphere Technologies, Inc. Stockholders Litigation

CourtCourt of Chancery of Delaware
DecidedDecember 6, 2021
DocketConsol. C.A. No. 2021-0025-JRS
StatusPublished

This text of In Re: Emisphere Technologies, Inc. Stockholders Litigation (In Re: Emisphere Technologies, Inc. Stockholders Litigation) 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: Emisphere Technologies, Inc. Stockholders Litigation, (Del. Ct. App. 2021).

Opinion

EFiled: Dec 06 2021 02:10PM EST Transaction ID 67145311 Case No. 2021-0025-JRS IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE

IN RE: EMISPHERE TECHNOLOGIES, ) CONSOLIDATED INC. STOCKHOLDERS LITIGATION ) C.A. No. 2021-0025-JRS

ORDER ESTABLISHING LEADERSHIP STRUCTURE

WHEREAS:

A. On November 5, 2020, Novo Nordisk A/S entered into an agreement to

acquire Emisphere Technologies, Inc. (“Emisphere”) as well as the royalty rights

owned by MHR Fund Management LLC (with its affiliates, “MHR”) for a total of

$1.8 billion (the “Merger”).

B. Two competing teams of Emisphere stockholders and their counsel seek to be

appointed to leadership roles in a consolidated action challenging the fairness of the

Merger on behalf of all stockholders of Emisphere who surrendered or sold their

Emisphere stock pursuant to the Merger, other than Defendants or their affiliates.

C. Under one proposal, Robert K. Brennan, Michael Goldberg, M.D., Stephen

Brandenburg, Samuel Menasha and James DeVilliers (the “Long-Term

Stockholders”) would serve as co-lead plaintiffs. Robbins Geller Rudman & Dowd

LLP and Friedlander & Gorris, P.A. would serve as co-lead counsel and Johnson

Fistel, LLP would serve as additional plaintiffs’ counsel. This team of plaintiffs and

counsel shall be referred to collectively as the “LTS Group.”

1 D. Under the other proposal, IsZo Capital LP (“IsZo”) would serve as lead

plaintiff. Bernstein Litowitz Berger & Grossmann LLP and Olshan Frome Wolosky

LLP would serve as co-lead counsel, and Abraham, Fruchter & Twersky, LLP and

Friedman Oster & Tejtel PLLC would serve as additional counsel. This team of

litigants and counsel shall be referred to collectively as the “IsZo Group.”

E. Nicolae Barbulescu, Kenneth Novick, Jack Barouh, and Eliot Houman

(collectively, the “Barbulescu Stockholders”) were Emisphere stockholders at the

time of the Merger. On January 11, 2021, the Barbulescu Stockholders filed the

Verified Stockholder Class Action Complaint in C.A. No. 2021-0025-JRS. George

Assad, Jr. (“Assad”) was also an Emisphere stockholder at the time of the Merger

and filed a Verified Class Action Complaint in C.A. No. 2021-0502-JRS on June 8,

2021. Both the Barbulescu Stockholders and Assad have filed joinders supporting

the IsZo Group.1 The IsZo Group has moved to appoint the Barbulescu

Stockholders and Assad as additional lead plaintiffs.

F. When faced with a leadership dispute, the court’s task is to “establish a

leadership structure that will provide effective representation.”2 To that end, the

1 Barbulescu Stockholders’ Joinder in Support of IsZo Capital LP’s Motion for Consolidation and Appointment of Lead Counsel (D.I. 3) (C.A. 2021-0497-JRS); George Assad, Jr.’s Joinder in Support of IsZo Capital LP’s Motion for Consolidation and Appointment of Lead Plaintiff and Co-Lead Counsel (D.I. 4). 2In re Del Monte Foods Co. S’holders Litig., 2010 WL 5550677, at *6 (Del. Ch. Dec. 31, 2010).

2 court weighs the “Hirt factors,” so named after Hirt v. U.S. Timberlands Service

Company, LLC.3 The six factors can be paraphrased as follows:

i. the quality of the pleading that appears best able to represent the interests of the shareholder class and derivative plaintiffs;

ii. the relative economic stakes of the competing litigants in the outcome of the lawsuit;

iii. the willingness and ability of all the contestants to litigate vigorously on behalf of an entire class of shareholders;

iv. the absence of any conflict between larger, often institutional, stockholders, and smaller stockholders;

v. the enthusiasm or vigor with which the various contestants have prosecuted the lawsuit; and

vi. the competence of counsel and their access to the resources necessary to prosecute the claims at issue.4

G. The Hirt factors provide guidance, but they are not a “scorecard.”5 “A

plaintiff’s firm does not ‘win’ the lead counsel spot by accumulating the most

‘points,’ as it might by demonstrating that its client owns the most shares or that it

has litigated the most [] cases [challenging mergers on the ground of fiduciary duty

3 2002 WL 1558342 (Del. Ch. July 3, 2002). 4 See id. at *2. 5 In re Delphi Fin. Gp. S’holder Litig., 2012 WL 424886, at *1 (Del. Ch. Feb. 7, 2012).

3 breaches]. Instead, each factor is given weight only to the extent that it bears on the

ultimate question of what is in the best interests of the plaintiff class.”6

H. For purposes of analysis, Delaware courts often group the Hirt factors into

categories based on whether they focus more closely on the proposed lead plaintiff

or the proposed lead counsel.7

1. Factors (ii) and (iv) address attributes of the proposed lead plaintiff. Factor (ii) considers whether the economic stake of the proposed plaintiff is relatively significant, likely leading to meaningful monitoring and reduced agency costs. Factor (iv) asks whether any particular attributes of the proposed plaintiff, such as unique defenses or potentially divergent interests, could diminish the plaintiff’s effectiveness.

2. Factors (i), (v), and (vi) address aspects of the proposed lead counsel’s ability to provide effective representation. Factors (i) and (v) look at two objective indicia of counsel’s ability based on their actions in the specific case—the pleading on which the law firm proposes to litigate and how counsel has acted in the case to date. Factor (vi) calls on the court to consider more generally which law firm is best qualified to handle the matter.

3. Factor (iii) blends the consideration of the law firm and the proposed lead plaintiff by requiring the court to consider how the litigation is likely to unfold and whether the proposed leadership team will operate effectively.

Upon applying the Hirt factors to the competing applications for leadership in

this case, it appears to the Court that:

6 Id. 7E.g., Del Monte Foods, 2010 WL 5550677, at *6 (noting that the factors are divided to “examine both the proposed lead counsel and the proposed named plaintiff”).

4 1. The LTS Group and the IsZo Group are closely matched. Both groups

are highly qualified and capable of litigating the case.

2. Lead plaintiff factor (ii) is neutral as between the two groups, and factor

(iv) slightly favors the LTS Group.

a. Factor (ii) asks the Court to consider the relative economic stakes

of the competing litigants in the lawsuit’s outcome. This court only accords “great

weight” to “substantial relative difference[s]” in the movants’ economic stakes; it

does not “simply add up the number of shares and select the [stockholder(s)] with

the largest absolute representation.”8 While “Hirt stands for the proposition that

relative economic stakes are given great weight, not simply economic stakes,”9

Delaware courts have also recognized that the “potential upside” of a large

stockholder is that it will typically “align its incentives with the rest of the class.”10

b. Here, when the Merger closed (the “Closing Date”), the Long-

Term Stockholders collectively owned over 2 million shares (worth nearly $16

million),11 and IsZo held almost 8 million shares (worth nearly $63 million)—

8 See Wiehl v. Eon Labs, 2005 WL 696764, at *3 (Del. Ch. Mar. 22, 2005). 9 Id. 10 Ryan v. Mindbody, Inc., 2019 WL 4805820, at *3 (Del. Ch. Oct. 1, 2019). 11 Verified Class Action Compl. (“LTS Compl.”) (D.I. 1) (C.A. 2021-0576-JRS) ¶¶ 16–20.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

In Re Revlon, Inc. Shareholders Litigation
990 A.2d 940 (Court of Chancery of Delaware, 2010)
BVF Partners L.P. v. New Orleans Employees' Retirement System
59 A.3d 418 (Supreme Court of Delaware, 2012)

Cite This Page — Counsel Stack

Bluebook (online)
In Re: Emisphere Technologies, Inc. Stockholders Litigation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-emisphere-technologies-inc-stockholders-litigation-delch-2021.