In a recent Chancery Court decision applying Section 220 of the DGCL, the court reiterated the requirements that must be satisfied in a demand for books and records. The proper purpose prerequisite in the statute requires that the stockholder establish a credible basis for the allegations of misconduct on which the demand is asserted (i.e., to establish a purpose related to status as a stockholder). The court also addressed the effect of a merger of the company after the demand was made. After a trial, which took place about a year after the initial demand was made, the court determined that a limited scope of documents (fewer than requested) should be produced. The opinion, Deephaven Risk Arb Trading, Ltd. v Unitedglobalcom, Inc., is available via downloaded pdf file.