In re Oracle Corporation Derivative Litigation

CourtCourt of Chancery of Delaware
DecidedFebruary 7, 2024
DocketCA No. 2017-0337-SG
StatusPublished

This text of In re Oracle Corporation Derivative Litigation (In re Oracle Corporation Derivative 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 Oracle Corporation Derivative Litigation, (Del. Ct. App. 2024).

Opinion

IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE

Consolidated IN RE ORACLE CORPORATION DERIVATIVE C.A. No. 2017-0337-SG LITIGATION

MEMORANDUM OPINION

Date Submitted: November 17, 2023 Date Decided: February 7, 2024

Joel Friedlander, Jeffrey M. Gorris, and David Hahn, FRIEDLANDER & GORRIS, P.A., Wilmington, Delaware; Christopher H. Lyons and Tayler D. Bolton, ROBBINS GELLER RUDMAN & DOWD LLP, Wilmington, Delaware; OF COUNSEL: Randall J. Baron and David A. Knotts, ROBBINS GELLER RUDMAN & DOWD LLP, San Diego, California; Gregory Del Gaizo, ROBBINS LLP, San Diego, California, Attorneys for Lead Plaintiffs Firemen’s Retirement System of St. Louis and Robert Jessup.

Blake Rohrbacher, Susan M. Hannigan, Matthew D. Perri, Daniel E. Kaprow, and Kyle H. Lachmund, RICHARDS, LAYTON & FINGER, P.A., Wilmington, Delaware, Attorneys for Nominal Defendant Oracle Corporation.

Elena C. Norman, Richard J. Thomas, and Alberto E. Chávez, YOUNG CONAWAY STARGATT & TAYLOR, LLP, Wilmington, Delaware; OF COUNSEL: Peter A. Wald, LATHAM & WATKINS LLP, San Francisco, California; Blair Connelly, LATHAM & WATKINS LLP, New York, New York, Attorneys for Defendants Lawrence J. Ellison and Safra A. Catz.

GLASSCOCK, Vice Chancellor I once described the situation of the entrepreneurial plaintiff’s firm in

derivative litigation thus:

The position of the Plaintiffs’ counsel is reminiscent of a rodeo bull- rider. The cowboy gets his bull by the luck of the draw. A “good” bull is aggressive and vigorous; a “bad” bull is the opposite. A successful ride of a good bull results in a high score. It takes a good rider to ride a good bull, but not even a great rider can wring a high score from a bad bull. Not even great counsel can wring significant stockholder value from litigation over an essentially loyal and careful sales process.1

Here, briefly, Oracle Corporation purchased NetSuite in 2016. Defendant

Larry Ellison was a founder and major blockholder of both companies. Because he

stood on both sides of the transaction, because he had great influence in the operation

of Oracle’s business, and because his interest in NetSuite was greater than his

interest in Oracle, the opportunity for self-dealing was apparent. Plaintiffs and

others, stockholders of Oracle, sued derivatively, alleging that Ellison and Oracle

CEO Safra Catz had caused Oracle to overpay for NetSuite, and that a majority of

Oracle’s board of directors were not independent of Ellison. The matter survived a

motion to dismiss; the Company then appointed two new independent directors who

composed the majority of a special litigation committee (the “SLC”), which

investigated and determined that it was in Oracle’s best interests that the suit go

forward to a resolution, under the derivative Plaintiffs and their counsel. Much

litigation ensued, the matter was tried over ten days, and ultimately, I found that

1 In re Xoom Corp. S’holder Litig., 2016 WL 4146425, at *5 (Del. Ch. Aug. 4, 2016). 1 Ellison had insulated himself from the transaction so that no liability attached. The

Complaint was amended five times, and I delivered seven memorandum opinions of

the Court.2 Plaintiffs ultimately recovered nothing from the transaction litigation.

After I found for Defendants, Plaintiffs moved for a mootness fee. They note

that during the pendency of the litigation, and (per Plaintiffs) in response thereto,

Oracle appointed two independent directors (the “New Directors”) referred to above,

who then served on the SLC. In Plaintiffs’ view, the litigation thus worked a

corporate benefit—increasing the percentage of independent directors—and

Plaintiffs are entitled to a mootness fee of $5 million, notwithstanding that

ultimately, Defendants prevailed in the litigation. Oracle disagrees, and the matter

has been briefed and argued.

It is Plaintiffs’ position that the fact of the post-trial defeat of their claims is

inconsequential—the benefit was complete when the two New Directors were

appointed, five years before my post-trial opinion was issued. Oracle counters that

the hiring of the New Directors was not caused by the litigation; and that, in any

event, any benefit would be negative when netted against the cost of the litigation to

Oracle. More fundamentally, Oracle points out that for a plaintiff to be entitled to

fees for creating a corporate benefit, either the benefit must result from a settlement

of claims or, if the benefit is worked without a settlement, there must be a nexus

2 See In re Oracle Corp. S’holder Litig., 2023 WL 3408772, at *16–17 (Del. Ch. May 12, 2023). 2 between the theory of the action and the benefit; and not, as they characterize it here,

a mere fortuity only tangentially related to the litigation.

I agree. The appointment of the New Directors did not moot any issues in the

case, nor was it an aim of Plaintiffs’ litigation. Assuming that there was a causal

relationship between the timing of the hiring of the New Directors and the

litigation’s survival of the motion to dismiss (which I do assume, without deciding)

the appointment was incidental to, not the aim of, the litigation. As Plaintiffs point

out, our courts have awarded fees under the corporate benefit doctrine for therapeutic

benefits reached in settlements, even where the therapeutic benefit was not sought

in the complaint. The benefit there was achieved through compromise of the claims

raised, however. Here, the matter was litigated through trial, unsuccessfully. The

appointment of the New Directors was not related to the causes of action raised in

the complaints themselves, and did not result from the compromise of those claims.

This jurisdiction follows the American Rule on fees; each party bears her own.

An exception occurs where the litigation works a common benefit on a class or a

corporate entity; equity then requires that the party creating the benefit for the entity

not unduly bear the burden. But that is not the case here. If Plaintiffs are correct

that the New Directors were engaged primarily to serve on the SLC in response to

Plaintiffs’ suit, that is not a benefit created by the efforts of Plaintiffs—it is merely

3 a collateral effect of this litigation, and awarding fees in this situation would create

an unwholesome incentive.

Plaintiffs, it proves, had a bad bull. The ride was long and skillfully done, but

not a winner. I feel sympathy for Plaintiffs’ counsel here, who proceeded

derivatively, in good faith and with great skill and vigor, at great cost and effort to

themselves. Moreover, the SLC—acting for the Company—decided that the

litigation was in the best interests of Oracle, and recommended the derivative action

go forward to determine whether damages were available.3 Nonetheless, this is

counsels’ business model: sue derivatively, on a contingency basis, accept the freight

in a losing case, while seeking a multiple of a lodestar in a successful one. The fact

that this case consumed monumental effort on the part of some of the best in the

plaintiffs’ bar, like the fact of my sympathy, does not change that.

My reasoning follows in more detail.

I. BACKGROUND

I limit my discussion of the facts to only those necessary to understand

my analysis.4

3 In that sense, the litigation presumably worked a benefit, in the eyes of the SLC at least, on behalf of Oracle.

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In re Oracle Corporation Derivative Litigation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-oracle-corporation-derivative-litigation-delch-2024.