Recent Delaware Supreme Court and Court of Chancery cases have continued to refine the impact and requirements of Corwin v. KKR Financial Holdings LLC, 1 in which the Delaware Supreme Court held that the business judgment rule is "the appropriate standard of review for a post-closing damages action when a merger that is not subject to entire fairness … has been approved by a fully informed, uncoerced majority of the disinterested stockholders." 2 Recent cases have focused on three areas: (1) the scope of the business judgment rule; (2) the adequacy of disclosures and coercion; and (3) the burdens of pleading and proof.