Roberta Ann K.W. Wong Leung Revocable Trust U/A Dated 03/09/2018 v. Amazon.com, Inc.

CourtCourt of Chancery of Delaware
DecidedNovember 5, 2025
DocketC.A. No. 2023-1251-BWD
StatusPublished

This text of Roberta Ann K.W. Wong Leung Revocable Trust U/A Dated 03/09/2018 v. Amazon.com, Inc. (Roberta Ann K.W. Wong Leung Revocable Trust U/A Dated 03/09/2018 v. Amazon.com, 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.

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Roberta Ann K.W. Wong Leung Revocable Trust U/A Dated 03/09/2018 v. Amazon.com, Inc., (Del. Ct. App. 2025).

Opinion

COURT OF CHANCERY OF THE STATE OF DELAWARE BONNIE W. DAVID COURT OF CHANCERY COURTHOUSE VICE CHANCELLOR 34 THE CIRCLE GEORGETOWN, DE 19947

Date Submitted: October 15, 2025 Date Decided: November 5, 2025

Samuel L. Closic, Esquire Garrett B. Moritz, Esquire Caitlin E. Whetham, Esquire Dylan T. Mockensturm, Esquire Prickett, Jones & Elliott, P.A. Benjamin M. Whitney, Esquire 1310 N. King Street Ross Aronstam & Moritz LLP Wilmington, DE 19801 1313 North Market Street, Suite 1001 Wilmington, DE 19801

RE: Roberta Ann K.W. Wong Leung Revocable Trust U/A Dated 03/09/2018 v. Amazon.com, Inc., C.A. No. 2023-1251-BWD

Dear Counsel:

This action concerns a stockholder demand to inspect the books and records of

Amazon.com, Inc. (“Amazon”). On July 28, 2025, the Delaware Supreme Court

issued an opinion holding that the stockholder plaintiff established a credible basis to

investigate purported anticompetitive conduct at Amazon. On remand, this letter

opinion addresses the scope of, and conditions on, the stockholder’s inspection. Roberta Ann K.W. Wong Leung Revocable Trust U/A Dated 03/09/2018 v. Amazon.com, Inc., C.A. No. 2023-1251-BWD November 5, 2025 Page 2 of 19

I. BACKGROUND

This Court and the Delaware Supreme Court have described the factual

background pertinent to this matter in three written decisions.1 The following

recitation includes only an overview of the facts necessary to understand the Court’s

ruling on the remaining issues of scope and conditions on inspection.

Roberta Ann K.W. Wong Leung Revocable Trust U/A Dated 03/09/2018

(“Plaintiff”) is a stockholder of Amazon, a Delaware corporation and multinational

technology enterprise focused on e-commerce, cloud computing, and digital

streaming.2 In October 2023, Plaintiff sent a letter to Amazon’s board of directors

demanding to inspect books and records under 8 Del. C. § 220 (the “Demand”), for

the purpose of “investigat[ing] potential corporate mismanagement, wrongdoing, and

waste” based on “concern[s] that Amazon’s fiduciaries have authorized or allowed

[Amazon to] take unlawful advantage of [its] dominant [marketplace] position to

1 Roberta Ann K.W. Wong Leung Revocable Tr. v. Amazon.com, Inc., 2025 WL 2104036 (Del. July 28, 2025) [hereinafter Sup. Ct. Op.]; Roberta Ann K.W. Wong Leung Revocable Tr. U/A Dated 03/09/2018 v. Amazon.com, Inc., 2024 WL 4564754 (Del. Ch. Oct. 24, 2024) [hereinafter Mem. Op.]; Roberta Ann K.W. Wong Leung Revocable Tr. U/A Dated 03/09/2018 v. Amazon.com, Inc., 2024 WL 1916089 (Del. Ch. May 1, 2024) [hereinafter Final Report]. Joint exhibits are cited as “JX __.” 2 JX 53 [hereinafter Demand] at 1; JX 81 at 4. Roberta Ann K.W. Wong Leung Revocable Trust U/A Dated 03/09/2018 v. Amazon.com, Inc., C.A. No. 2023-1251-BWD November 5, 2025 Page 3 of 19

engage in anticompetitive practices, leading to U.S. and international regulatory

scrutiny, lawsuits, and fines.”3

Amazon responded to the Demand, asserting that the Demand failed to state a

proper purpose and was overbroad in scope, but nevertheless offering to produce “a

targeted set of materials” with the caveat that “[a]ny such production would be

conditioned on the prior execution of a suitable confidentiality agreement.”4 Amazon

proposed a confidentiality agreement that imposed, among other conditions, a

jurisdictional restriction limiting use of the inspection materials in litigation to a

Delaware forum (a “Forum Restriction”).5 Plaintiff refused to agree to a Forum

Restriction.6

On December 14, Plaintiff filed this action, and the Court held a one-day trial

on a paper record on April 26, 2024.7 On May 1, while serving as a Magistrate in

Chancery, I issued a post-trial final report (the “Final Report”) in which I concluded

that Plaintiff failed to meet its burden to state a proper purpose for inspection by

3 Demand at 1. 4 JX 60 at 2–3. 5 JX 49 ¶ 14. 6 JX 58 at 1. 7 Dkt. 56. Roberta Ann K.W. Wong Leung Revocable Trust U/A Dated 03/09/2018 v. Amazon.com, Inc., C.A. No. 2023-1251-BWD November 5, 2025 Page 4 of 19

demonstrating a credible basis to investigate wrongdoing. Final Report at *8–9. I

therefore recommended that judgment be entered for Amazon. Id. at *9. Plaintiff

filed exceptions to the Final Report, which were assigned to Vice Chancellor Will. 8

On October 24, Vice Chancellor Will issued a memorandum opinion (the

“Memorandum Opinion”) overruling the exceptions, denying inspection on the basis

that Plaintiff’s stated purpose was so overbroad that it was facially improper. Mem.

Op. at *1.

Plaintiff appealed the Final Report and the Memorandum Opinion.9 On July

28, 2025, the Delaware Supreme Court issued an opinion (the “Opinion”) reversing

this Court’s denial of Plaintiff’s inspection. Sup. Ct. Op. at *11. In the Opinion, the

Supreme Court concluded that Plaintiff had reasonably limited the scope of its

Demand before trial by “identif[ying] the specific examples of purported

anticompetitive conduct that [Plaintiff] sought to investigate[,]” “clarify[ing] the

scope of its requested inspection to ‘regulatory inquiries or lawsuits in the U.S. and

Europe[,]’” and identifying an “appropriate timeframe” for the Demand of

“September 2018 through the present.” Id. at *8 (quoting Pl.’s Answering Pre-Trial

Br. at 14–15, Dkt. 47).

8 Dkts. 60–61. 9 Dkt. 78. Roberta Ann K.W. Wong Leung Revocable Trust U/A Dated 03/09/2018 v. Amazon.com, Inc., C.A. No. 2023-1251-BWD November 5, 2025 Page 5 of 19

The Supreme Court’s Opinion further concluded that Plaintiff had “satisfied its

burden of proving a credible basis, especially considering . . . developments” that

occurred after the Final Report was issued. Id. Specifically, the Supreme Court found

that, “taken together, [an] FTC action, [a] State of California action, [a] State of

Washington consent decree, and [an] Italian Competition Authority fine [we]re

sufficient to establish a credible basis from which [the] court c[ould] infer that

Amazon has engaged in possible wrongdoing through its purported anticompetitive

activities.” Id. at *11. Accordingly, the Supreme Court concluded that Plaintiff stated

a proper purpose for the Demand. Id.

The Supreme Court reversed and remanded for further proceedings to

determine scope and conditions on inspection. Id. On October 15, the parties filed

supplemental briefs addressing those issues.10

II. ANALYSIS

Two issues remain for resolution on remand. First, the Court must decide the

scope of Plaintiff’s inspection, and second, the Court must determine any conditions

on the inspection.

10 Def. Amazon.com, Inc.’s Suppl. Br. [hereinafter DB], Dkt. 88; Pl.’s Post-Appeal Br. [hereinafter PB], Dkt. 89. Roberta Ann K.W. Wong Leung Revocable Trust U/A Dated 03/09/2018 v. Amazon.com, Inc., C.A. No. 2023-1251-BWD November 5, 2025 Page 6 of 19

A. Scope Of Inspection

“The scope of inspection is a fact-specific inquiry, and the court has broad

discretion when conducting it.” Hightower v. SharpSpring, Inc., 2022 WL 3970155,

at *8 (Del. Ch. Aug. 31, 2022). The stockholder plaintiff “bears the burden of proving

that each category of books and records is essential to accomplishment of the

stockholder’s articulated purpose for the inspection.” KT4 P’rs LLC v. Palantir Techs.

Inc., 203 A.3d 738, 751 (Del. 2019) (quoting Thomas & Betts Corp. v.

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Roberta Ann K.W. Wong Leung Revocable Trust U/A Dated 03/09/2018 v. Amazon.com, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/roberta-ann-kw-wong-leung-revocable-trust-ua-dated-03092018-v-delch-2025.