In the matter of Shanda Games Ltd [2017] CIFsd 16 (25 April 2017)

In the matter of Shanda Games Ltd [2017] CIFsd 16 (25 April 2017)

The court held that fair value under section 238 of the Companies Law must be determined without applying a minority discount, as the statutory appraisal process is designed to ensure minority shareholders receive the full pro rata value of their shares in the context of a merger.

Citation
[2017] CIFsd 16
Parties
Respondent: Shanda Games Ltd; Applicant: Minority Shareholders
Jurisdiction
Cayman Islands
Judgment Date
25 April 2017
Procedural Posture
Company Law Petition / Final Judgment
Outcome
judgment for applicant
Legal Topics
Fair Value Determination, Minority Shareholder Rights, Statutory Appraisal, Mergers and Acquisitions

Case Brief

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Parties

Shanda Games Ltd

Respondent

Minority Shareholders

Applicant

Procedural Posture

Company Law Petition / Final Judgment

  1. 1 What is the fair value of shares held by dissenting minority shareholders in Shanda Games Ltd following a merger?
  2. 2 Should the court apply a minority discount in determining fair value under section 238 of the Companies Law?

Ratio Decidendi

The court held that fair value under section 238 of the Companies Law must be determined without applying a minority discount, as the statutory appraisal process is designed to ensure minority shareholders receive the full pro rata value of their shares in the context of a merger.

Court Disposition

judgment for applicant

Orders

  • Shanda Games Ltd is ordered to pay dissenting shareholders the fair value of their shares without applying a minority discount.
  • Costs awarded to the applicants.