In Ravenswood Investment Co. v. Winmill & Co., No. 7048 (Del. Ch. Jan. 31, 2013), the Delaware Chancery Court held that a fiduciary duty claim and a demand for inspection of company books and records under Section 220 cannot be combined in a single proceeding. The court reasoned that the two types of claims are distinct and proceed at a different pace: “Books and records actions are supposed to proceed summarily. The companion fiduciary duty claims would slow the pace. The Section 220 and fiduciary duty claim should not have been brought together.”