Mooney v. Echo Therapeutics, Inc., C. A. No. 10054-VCP (Del. Ch. May 28, 2015). This is one of two Chancery decisions in separate matters handed down today on the issue of advancement of fees for directors. Noteworthy is the Order the Court issued on the same date as the opinion, requiring what are now well-established procedures for the parties to submit bills for advancement, and to object to such requests, prior to submitting disputes over the amount, or scope, of bills to the Court. The Court’s formal opinion is notable for its treatment of the limits on the types of litigation subject to advancement when the litigation is offensive in nature as opposed to the typical circumstance where a director seeks advancement for fees incurred to defend a suit filed against her. Although well-established case law allows for advancement of fees incurred for certain counterclaims that are compulsory in nature, this case addresses a suit that was allegedly filed in response to claims asserted in a separate suit.