A recent Delaware decision is notable for two reasons. First, it provides an example of a relatively rare defamation finding in a decision by the Delaware Court of Chancery. In Laser Tone Business Systems, LLC v. Delaware Micro-Computer LLC, C.A. No. 2017-0439-TMR (Del. Ch. Jan. 17, 2020), the court granted damages in the amount of $100,000 for slander and libel per se. The defamation claim arose in the context of a counterclaim by an ex-employee who was sued by his former employer. The court described the award, that it determined in its discretion to be an appropriate amount, as compensating for injury resulting from the defamatory statements that included lost jobs, customers and friends.

Secondly, this ruling is notable as a reminder that motions for reargument are rarely successful, and this motion under Rule 59(f) is no exception.

Lastly, as an aside on a procedural note, the decision on which reargument was sought, styled Laser Tone Business Systems, LLC v. Delaware Micro-Computer LLC, 2019 WL 6726305 (Del. Ch. Nov. 27, 2019), was written by Justice Montgomery-Reeves when she was a Vice Chancellor, but Her Honor wrote this decision on the motion for reargument after she recently became a Justice of the Delaware Supreme Court (but the case is still referenced as a Chancery case).