On June 27, 2023, the Delaware Court of Chancery in Simeone v. The Walt Disney Company held that a stockholder’s disagreement with a corporation’s decision to speak on public policy did not constitute a “proper purpose” for making a books and records demand under Delaware law. Vice Chancellor Will found that “choosing to speak (or not speak) on public policy issues”—even divisive ones—is an exercise of business judgment rather than evidence of wrongdoing.