Since the Delaware Supreme Court issued its landmark Dell appraisal decision (see prior coverage), the Delaware courts have issued three appraisal decisions—Aruba, AOL, and SWS—which, unlike Dell, assigned no weight to the deal price in setting fair value below the deal price. A Fried Frank M&A/PE Briefing discusses the new trend of below-the-deal-price appraisal results, analyzes the likely practical impact, and offers related practice points.