the decision was for the benefit of the company’. US law Geyer v. Ingersoll Publication Co., 621 A.2d 784 (Del. Ch. 1992); Credit Lyonnais Bank Netherland, N.V. v. Pathe Communication Corp., Civ. A. No. 12150, 1991 WL 277613, at 34 n.55 (Del. Ch. Dec. 30, 1991) North American Catholic Education Programming Foundation, Inc. v. Gheewalla, 930 A.2d 92 (Del. 2007) denying direct fiduciary claims against directors by creditors and limiting these duties to situations where the firm is already insolvent References J Lowry, 'The Recognition of Directors Owing Fiduciary Duties to Creditors' (2004) International Corporate Rescue United Kingdom company case law United Kingdom insolvency case law High Court of Justice cases 2002 in case law 2002 in British law