In Delaware, a stockholder plaintiff is entitled to attorneys’ fees and expenses when “(i) meritorious litigation is filed, (ii) an action producing a benefit to the corporation or its stockholders is taken by the defendants before judicial resolution is achieved, and (iii) the resulting benefit is causally related to the litigation. . . .” Sutherland v. Sutherland, No. 2399 (Del. Ch. July 31, 2014). In Sutherland, at the end of “an acrimonious family dispute which ha[d] been actively litigated for ten years,” where the plaintiff ultimately lost on all of her claims, the plaintiff nonetheless sought fees from the nominal defendant companies. The Sutherlandplaintiff asserted that even though her lawsuit was unsuccessful on the merits, it caused the nominal defendants to amend employment agreements with the plaintiffs’ brothers, which yielded in excess of $1.4 million in benefits to the nominal defendants. The plaintiff also sought fees on the basis that her lawsuit “achieved a change in corporate culture” by forcing the defendants to “hold annual meetings and more openly provide information” to stockholders. The court rejected the argument that the lawsuit created a “change in corporate culture,” finding those allegations “amorphous and  difficult to quantify,” but held that the amendments to the employment agreements were a “positive benefit for the companies.” As a consequence, it awarded plaintiff $275,000 in fees and costs notwithstanding that the plaintiff had lost on the merits on all of her claims.