Brautigam v. Dahlback

SUMMARY ORDER

Plaintiff-Appellant Michael G. Brauti-gam appeals from the district court’s Opinion & Order, dated March 26, 2014, granting Defendants-Appellees’ motion to dismiss. We assume the parties’ familiarity with the underlying facts, procedural history, and issues for review.1

Appellant argues that the district court erred by evaluating his demand futility argument under Rales v. Blasband, 634 A.2d 927 (Del.1993), which, in derivative cases that do not involve a challenge to an action by the company’s board of directors, requires courts to determine whether there is a “reasonable doubt…