In King v. DAG SPE Managing Member, Inc., No. 7770 (Del. Ch. Dec. 23, 2013), the Delaware Chancery Court dismissed a former director’s demand for books and records under 8 Decl. C. § 220(d).  The plaintiff alleged that, without his knowledge, he had been named as an independent director of the defendant, DAG for at least a three-year period in the early 2000s.  In an effort to investigate actions taken by DAG during that period, the plaintiff made a request to inspect the defendant’s books and records.  DAG refused the request for inspection, and this action followed.  In dismissing the plaintiff’s complaint, the court held that Delaware common law did not granted plaintiff a right to request the defendant’s books and records, and under Delaware’s statute, “only current directors have inspection rights.”  Thus, “once a director of  Delaware corporation properly is removed from office, that individual’s right to inspect books and records of the corporation involved under Section 220(d) ends.”