to protect or maintain the corporate enterprise but to sell it to the highest bidder. Given that factual and legal backdrop, the court concluded that the Revlon board impermissibly ended the "intense bidding contest on an insubstantial basis." As a result, not only did the board's activities fail the new Revlon standard, but they also failed the Unocal standard. This opinion was written by Justice Andrew G.T. Moore. Resulting legal framework Today, there are three levels of judicial review when an action is brought under the allegation of a breach of fiduciary duties. As the court in Golden Cycle, LLC v. Allan stated, these levels are: "the deferential business judgment rule, the Unocal or Revlon enhanced scrutiny standard [and] the stringent standard of entire fairness." The first and most deferential standard, the business judgment rule, has become virtually a rubber-stamp in Delaware corporate law for corporate boards to meet their duty of care. It is the default standard (i.e., the facts must demonstrate why there should be a deviation from this level of review). The business judgment rule provides a rebuttable presumption "that in making a business decision the directors of a corporation acted on an informed basis, in good faith and in the honest belief that the action taken was in the best interests of the company." Thus, at bottom, the business judgment rule reflects little more than process inquiry. The Unocal and Revlon standards are similar in that they involve a reasonableness inquiry by the court and are triggered by some factual events. The Unocal standard is focused on the erection of defensive tactics by the target board, and involves reasonableness review of legitimate corporate threat and proportionality. The board's case is materially advanced when it can demonstrate that the board was independent, highly informed, and acted in good faith. Revlon duties, on the other hand, are triggered by what may be loosely referred to as a "change in control", and require a general reasonableness standard. This reasonableness standard requires virtually absolute independence of the board, careful attention to the type and scope of information to be considered by the board, good faith negotiation, and a focus on what constitutes the best value for the shareholders. Finding the best value for shareholders may or may not require an auction, depending on the circumstances, and, again, this decision is subjected to a reasonableness inquiry. The entire fairness standard is