The Chancery Court had granted an injunction against a stockholder vote for a proposed merger between C&J Energy Services and a third party, and ordered the C&J board to shop C&J to other potential suitors.  The Chancery Court found that in not shopping itself to other potential suitors, the C&J board violated its duties under Revlon, which requires a board that engages in a “change of control transaction” to “not take actions inconsistent with achieving the highest immediate value reasonably attainable.”  The Delaware Supreme Court reversed. C&J Energy Servs., Inc. v. City of Miami Gen. Emps’. & Sanitation Emps’. Ret. Trust, No. 655/657, 2014, (Del. Dec. 19, 2014).  The court stated that “[t]here is no single blueprint that a board must follow to fulfill its duties” under Revlon.  Rather, Revlon requires an analysis of whether “the directors made a reasonable decision, not a perfect decision.”  Thus, Revlon does not necessarily require “an active solicitation” of a company “so long as interested bidders have a fair opportunity to present a higher-value alternative, and the board has the flexibility. . .to accept” that higher-value deal, and thus the Chancery Court erred by holding the defendant directors to “legally prescribed steps that directors must follow to satisfy the Revlon duties.”  Such an approach was too rigid and “ignore[d] the Court of Chancery’s own well-reasoned precedent and that of [the Supreme] Court,” which required a more flexible analysis.