We’ve already seen other states apply their own appraisal statutes; we’ve covered Nevada before, for example.  We’re now also seeing other courts look to Delaware courts for the tools and methods behind valuation methods as well, not only in appraisal actions.  Thus, for example, an Arizona appeals court has cited Delaware appraisal cases in adjudicating

The so-called market-out exception precludes appraisal where the target’s stock trades in a highly liquid market.  In other words, appraisal is normally available to shareholders except, as the rationale goes, where the M&A target’s stock trades in such a liquid, highly efficient market that its stock price naturally reflects its fair value, and any