In last week’s BVWire, we covered a recent court ruling involving Dole Foods and a technique known as “appraisal arbitrage.” This strategy involves acquiring stock in a company that’s a takeover target. Then, the investors try to squeeze more money from the buyers by opposing the takeover and petitioning the court for a fair value appraisal.

According to a report in The Wall Street Journal, this technique has gained popularity, with a “record 33 appraisal claims stemming from public-company takeovers … filed last year in Delaware.” Expect to see more of this, according to Kevin Abrams, a lawyer for Merion Capital LP, which has $750 million tied up in pending lawsuits. “Sophisticated investors are seeing significant valuation gaps in certain deal prices,” he told WSJ.

The report also cites research from law firm Fish & Richardson PC finding that about 81% of Delaware appraisals that went to trial since 1993 have yielded higher prices.