On June 20th, the Delaware Supreme Court held that a Delaware firm need not suffer actual harm to recover for its fiduciaries' insider trading under Brophy v. Cities Services Co. Appellants in this derivative action are shareholders of Primedia who appeal the Chancery Court's dismissal of their claims arising from a series of alleged violations of fiduciary duty by defendants, KKR, Primedia, and Primedia officers and directors. Because the Chancery Court improperly held that the purpose of a Brophy claim is to remedy a harm to the corporation, the Delaware Supreme Court reverses dismissal and remands. Kahn v. Kolberg, Kravis Roberts & Co., L.P.