Calma v. Templeton (Del. Ch. Apr. 30, 2015), which involved Citrix Systems, Inc., is the second significant Delaware Court of Chancery opinion in recent years to deal with equity compensation paid to directors. Seinfeld v. Slager (Del. Ch. Jun. 29, 2012), decided in 2012, was the first. In both Calma and Seinfeld, the Court denied the defendant’s motion to dismiss. In each case the denial turned to some extent on the absence from the relevant company’s equity plan of a meaningful limit on the number of shares that directors could receive as compensation. At least one similar case—relating to director compensation at the Goldman Sachs Group—has been filed in Delaware since the opinion in Calma was issued. As a result of these cases, companies putting new plans to a shareholder vote would be well advised to consider adding to those plans a meaningful limit on director equity compensation.