In Boilermakers Local 154 Retirement Fund v. Chevron Corp., No. 7220 (Del. Ch. June 25, 2013), the Delaware Court of Chancery held that a forum selection provision in bylaws requiring that litigation relating to the internal affairs of the corporation must be filed only in Delaware was enforceable. Plaintiffs challenged the provisions in the bylaws of Chevron Corporation and FedEx Corporation, arguing that they were not adopted by the shareholders but rather were unilaterally adopted by the boards using the boards’ power to make bylaws. The court held that the bylaws comported with Delaware statutory law because the bylaws “plainly relate to the ‘business of the corporation[s],’ the ‘conduct of their affairs,’ and regulate the ‘rights or powers of their stockholders.’” The court concluded that the bylaws also were contractually valid because “an essential part of the contract stockholders assent to when they buy stock in Chevron and FedEx is one that presupposes the board’s authority to adopt binding bylaws consistent with 8 Del. C. § 109.”