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Business Organizations Keyed to Allen
Fir Tree Value Master Fund, LP v. Jarden Corp.
Citation:
236 A.3d 313 (Del. 2020).Facts
Jarden was founded in the early 2000’s and acted as decentralized holding company for several consumer product brands. Newell operated in a similar fashion and in 2014 began actively searching for merger and acquisition deals. Representatives from Newell and Jarden met and, on October 28, 2015, Jarden’s board held a meeting to discuss a possible Newell transaction. After months of negotiations, the merger was approved on April 15, 2016 and Jarden’s stock was valued at $59.21 per share.
After closing, Fir Tree sought appraisal. Fir Tree’s experts argued the fair value on the date of closing was $71.35, but Jarden experts argued it was $48.01. Thereafter, the Court of Chancery determined the fair value was Jarden’s unaffected market price on the date of closing: $48.31.
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