The New York Times, had an article here,  yesterday  that summarized a study indicating that activist hedge funds that take aggressive roles in corporate governance issues often have a positive long-term impact that results in increasing shareholder value for the "average" investor. This may be a useful study, perhaps, to cite for hedge funds seeking, for example, to obtain books and records in an action under DGCL Section 220, when issues of "proper purpose" are contested.