Roberta Ann K.W. Wong Leung Revocable Trust U/A Dated 03/09/2018 vs Amazon.com, Inc.

103, 2026Del

Full text

IN THE SUPREME COURT OF THE STATE OF DELAWARE
ROBERTA ANN K.W. WONG
LEUNG REVOCABLE TRUST
U/A DATED 03/09/2018,
Plaintiff Below,
Appellant,
v.
AMAZON.COM, INC.,
Defendant Below,
Appellee.
§
§ No. 103, 2026
§
§ Court Below–Court of
§ Chancery of the State of
§ Delaware
§
§ C.A. No. 2023-1251
§
§
§
§
§
Submitted: September 30, 2026
Decided: October 13, 2026
Before LEGROW, GRIFFITHS, and ZURN, Justices.
ORDER
After careful consideration of the parties’ briefs and the record on appeal, and
following oral argument, we find it evident that the judgment below should be
affirmed on the basis of and for the reasons stated in the Court of Chancery’s Letter
Opinion dated November 5, 2025.1
1 By affirming, we reject Appellant’s argument that a court considering a forum restriction
must limit its inquiry to the factors identified in United Technologies Corp. v. Treppel. 109 A.3d
553, 560 (Del. 2014). As Treppel itself states, the court has broad discretion to evaluate conditions
on inspection based on case-specific facts. Id. at 557–60, 562.
We also respond briefly to two other arguments raised on appeal. First, inquiring into the
stockholder’s need to file suit outside of Delaware as one of those case-specific facts does not
improperly require the stockholder to commit to the ends of its inspection; this inquiry merely asks
the stockholder to identify where litigation may be filed, not how the stockholder may use the
books and records. See Lebanon Cnty. Emps.’ Ret. Fund v. AmerisourceBergen Corp., 2020 WL
132752, at *12 (Del. Ch. Jan. 13, 2020). Second, on this record, Court of Chancery Rule 60(b)
2
NOW, THEREFORE, IT IS ORDERED that the judgment of the Court of
Chancery is AFFIRMED.
BY THE COURT:
/s/ N. Christopher Griffiths
Justice
and the ability to seek expedition provide a sufficient safety valve to this forum restriction. See
Treppel, 109 A.3d at 560.

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