Robert A. Davidow v. Dov Seidman

CourtSupreme Court of Delaware
DecidedDecember 19, 2024
Docket464, 2024
StatusPublished

This text of Robert A. Davidow v. Dov Seidman (Robert A. Davidow v. Dov Seidman) is published on Counsel Stack Legal Research, covering Supreme Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Robert A. Davidow v. Dov Seidman, (Del. 2024).

Opinion

IN THE SUPREME COURT OF THE STATE OF DELAWARE

ROBERT A. DAVIDOW and § HOWARD MARKS, § § No. 464, 2024 Plaintiffs Below, § Appellants, § Court Below—Court of Chancery § of the State of Delaware v. § § C.A. No. 2019-0150 DOV SEIDMAN, LEE FELDMAN, § and MATS LEDERHAUSEN, § § Defendants Below, § Appellees. §

Submitted: November 12, 2024 Decided: December 19, 2024

Before SEITZ, Chief Justice; LEGROW and GRIFFITHS, Justices.

ORDER

Upon consideration of the notice of interlocutory appeal, the supplemental

notice, and the exhibits attached thereto, it appears to the Court that:

(1) This interlocutory appeal arises from complications in consummation

of a class action settlement. In 2019, Robert A. Davidow, a stockholder of LRN

Corporation, filed a class action complaint alleging breaches of fiduciary duty by

LRN directors Dov Seidman, Lee Feldman, and Mats Lederhausen (“the

Defendants”) in connection with a 2017 tender offer. Another LRN stockholder,

Howard Marks, intervened in 2020. After mediation in May 2022, the parties

executed a settlement term sheet in November 2022 and filed a settlement stipulation in May 2023. At the September 7, 2023 settlement hearing, the Court of Chancery

ruled that Davidow and Marks (“the Original Plaintiffs”) were inadequate class

representatives because Davidow had engaged in spoliation of evidence and Marks

had published false pleadings and then used his representative status to negotiate the

release of a personal defamation action filed against him (“the Adequacy Ruling”).

(2) On September 13, 2023, the Original Plaintiffs moved for enlargement

of the time to file an application for certification of an interlocutory appeal while

they evaluated whether a new class member could become a class representative.

The court enlarged the time to ten business days after the court declined to (i) grant

a motion to join a new lead plaintiff, (ii) certify a new class representative, (iii)

certify a class, or (iv) approve the settlement, if a class was certified, whichever date

was later.

(3) Class members Kevin Boylan, Stephen Paluszek, and Marc Rapaport

(“the New Plaintiffs”) then moved to lift the stay in place since the parties had

pursued mediation and to intervene so that they could pursue certification as class

representatives, class certification, and approval of the settlement. The Defendants

opposed intervention as well as class certification and sought confirmation from the

court that they could make settlement offers to individual class members. On June

5, 2024, the court granted the New Plaintiffs’ motion and declined to consider the

Defendants’ request.

2 (4) On August 10, 2024, the Original Plaintiffs and the New Plaintiffs

moved to enforce the settlement stipulation and for issuance of a rule to show cause

based on the Defendants’ alleged breaches of the settlement stipulation. The

Defendants opposed the motion. On October 9, 2024, the court denied the motion

in a bench ruling (“Enforcement Ruling”).

(5) On October 21, 2024, the Original Plaintiffs filed an application for

certification of an interlocutory appeal from the Adequacy Ruling. The Original

Plaintiffs and New Plaintiffs filed an application for certification of an interlocutory

appeal from the Enforcement Ruling. The Defendants opposed both applications.

(6) On November 6, 2024, the Original Plaintiffs filed this interlocutory

appeal from the Adequacy Ruling. On November 12, 2024, the Court of Chancery

denied both applications for certification.

(7) In denying certification of the Adequacy Ruling, the Court of Chancery

first found that the fact-specific determination concerning whether the Original

Plaintiffs were adequacy class representatives was procedural and did not decide a

substantive legal right. The court next considered the Rule 42(b)(iii) criteria,

focusing on the criteria identified by the Original Plaintiffs as supporting

certification. As to Rule 42(b)(iii)(G) (review of the interlocutory order may

terminate the litigation), the court rejected the Original Plaintiffs’ contention that

review of the Adequacy Ruling would terminate the litigation. The court found that

3 it would still have to consider whether the other requirements of class certification

had been satisfied, noting that it had questioned numerosity and commonality at the

September 7, 2023 hearing. The court would also have to decide whether the

settlement was fair, including the release of the defamation action against Marks.

(8) Turning to Rule 42(b)(iii)(H) (review of the interlocutory order may

serve considerations of justice), the court acknowledged the risk to innocent class

members if the settlement payment and the efficiencies of a class structure were lost.

But the court recognized that the Defendants had previously expressed their intent

to make the same pro rata settlement offer each class member (except Marks) and

concluded that the Original Plaintiffs had not shown that review of the Adequacy

Ruling would serve considerations of justice. After the court denied the applications

for certification, the Defendants notified the court that they did not presently intend

to make a settlement offer to any of the class members.

(9) Initially, we note that that this interlocutory appeal appears to be

untimely. Rule 42(d)(i) requires the appellant to file a notice of appeal from an

interlocutory order “within 30 days after the entry of the order from which the appeal

is sought to be taken.”1 The Court of Chancery ruled that the Original Plaintiffs

were inadequate class representatives on September 7, 2023, but the Original

1 Super. Ct. R. 42(d)(i). See also Supr. Ct. R. 6(a)(i) (requiring that a notice of appeal be filed within 30 days after entry upon the docket of the judgment or order from which the appeal is taken). 4 Plaintiffs did not file their notice of interlocutory appeal from this ruling until

November 6, 2024.

(10) The Original Plaintiffs state in their notice of appeal that no order

implementing the Adequacy Ruling was entered, but the Court of Chancery did not

direct the parties to submit a form of order for the Adequacy Ruling. In addition,

the Original Plaintiffs recognized that September 7, 2023 was the relevant date for

purposes of Rule 42 when they moved for enlargement of the ten-day time period to

file their application for certification on September 13, 2023.2 Rule 42 allows the

trial court to enlarge the ten-day time period for filing an application for certification,

but does not authorize the trial court to extend the thirty-day time period to file an

interlocutory appeal in this Court.3

(11) Assuming that this interlocutory appeal is timely, the Court will not

accept it. Applications for interlocutory review are addressed to the sound discretion

2 Id. 42(c)(i) (providing that the application for certification shall be filed in the trial court “within 10 days of the entry of the order from which the appeal is sought or such longer time as the trial in court, in its discretion, may order for good cause shown”). 3 Id. 42(d)(i) (“The notice of appeal may be filed at any time after the filing of the application for certification in the trial court, except that it shall be the obligation of appellant to serve and file in this Court a notice of appeal of an interlocutory order within 30 days after the entry of the order from which the appeal is sought to be taken.”).

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Robert A. Davidow v. Dov Seidman, Counsel Stack Legal Research, https://law.counselstack.com/opinion/robert-a-davidow-v-dov-seidman-del-2024.