Cellular Telephone: An Interesting Decision for Valuation Practitioners

Business Valuation UpdateVol. 28 No. 6
June 2022
Gilbert E. Matthews, MBA, CFA
shareholder dissent/oppression
breach of fiduciary duty, buyout, cash flow, entire fairness, minority shareholder, projections, growth rate, burden of proof, distributions


A recent Delaware decision in a breach of fiduciary duty case awarded more than triple the amount originally paid to partners who were squeezed out of their collective 1.881% interest in a partnership. Several aspects of this decision are of particular interest to valuation practitioners, especially those whose practice includes litigation services. The case is: In Re Cellular Tel. P’ship Litig.; 2022 Del. Ch. LEXIS 56 (Cellular).