In the 25 years since Caremark was decided, the Delaware courts have repeatedly emphasized that claims for breach of the duty of loyalty premised on lack of oversight are exceedingly difficult to plead. In order to state a Caremark claim, a plaintiff must "plead with particularity that the board cannot be entrusted with the claim because a majority of the directors may be liable for oversight failures," which is "extremely difficult to do." 4 In fact, Delaware jurisprudence suggests that "the claim that corporate fiduciaries have breached their duties to stockholders by failing to monitor corporate affairs is 'possibly the most difficult theory in corporation law upon which a plaintiff might hope to win a judgment.'" 5 As a result, oversight claims have been few and far between and, when such claims were brought, they rarely survived motions to dismiss.