Last month, we saw authors calling appraisal a maze, and now, an analogy to a sculpture.  In the journal M&A Law [$$], April 2018 edition, authors from Wilson Sonsini write about how recent Delaware cases have shaped and sculpted the appraisal remedy, but left open a number of issues for future decisions.  Citing Aruba, AOL, DFC, and Dell, the authors conclude that deal synergies and market efficiency will take on increased importance and prominence in appraisal jurisprudence.

Whether appraisal is best described as a maze or sculpture, recent decisions have shown that the facts of each individual merger matter and that no one-size-fits-all rule applies.