The Delaware stockholder appraisal action (a statutory cause of action) has become an increasingly common method for hedge fund managers to generate investment returns. In appraisal actions, managers hold shares in a corporation and dissent from a proposed merger or consolidation, using litigation to significantly increase the value of those shares. Following pressure from the defense bar, it was believed that the Delaware legislature and courts were eager to rein in stockholders’ appraisal rights. But the enactment of Delaware Bill No. 371 (HB 371) and the Court of Chancery’s recent decision in In re Appraisal of Dell, Inc. (In re Dell) indicate that the right to appraisal is alive and well, confirming that this litigation-based investment strategy remains a suitable option for hedge fund managers. In a guest article following their earlier piece discussing the viability of the appraisal rights strategy for hedge fund managers, Ben Quarmby, a partner at MoloLamken, and Hassan A. Shah, a senior associate at Rock Creek Partners, analyze the changes introduced by HB 371 and In re Dell, along with the likely impact of those changes on shareholder appraisals. For additional insight from Quarmby, see “Measures Hedge Fund Managers Can Implement to Maximize Protection of Their Trade Secrets” (Dec. 6, 2012). For commentary from other MoloLamken practitioners, see “The SEC’s Pay to Play Rule Is Here to Stay: Tips for Hedge Fund Managers to Avoid Liability” (Oct. 8, 2015); “FCPA Considerations for the Private Fund Industry: An Interview with Former Federal Prosecutor Justin Shur” (May 23, 2014); and “How Private Fund Managers Can Manage FCPA Risks When Investing in Emerging Markets” (Jan. 10, 2013).