presentation for approval of shareholders. Even actions by independent boards in such circumstances that fail to evidence a reasonable effort and intent to secure the highest and best price reasonably available are likely to invoke searching judicial scrutiny. However, recent Delaware litigation deferred to an independent's board decisions to not engage in negotiations with a competing bidder to try to obtain improved terms after a merger agreement had been signed. See also Fiduciary duty Poison pill Cheff v. Mathes, 199 A.2d 548 (Del. 1964) Paramount v. Time (Del. 1989) Unocal Corp. v. Mesa Petroleum Co., 493 A.2d 946 (Del. 1985) Weinberger v. UOP, Inc., 457 A.2d 701 (Del. 1983) Notes Further reading Equity-Linked Investors, LP v. Adams, 705 A.2d 1040, 1054 (Del. Ch. 1997) (tracing the history of Revlon duties and concluding that one view of Revlon led to a severe curtailment in the range of board business discretion) Melissa M. Kurp, Corporate Takeover Defenses After QVC: Can Target Boards Prevent Hostile Tender Offers Without Breaching Their Fiduciary Duties?, 26 Loy. U. Chi. L.J. 29, 33 (1994) (noting the takeover frenzy of the 1980s). External links United States corporate case law Delaware state case law 1986 in United States case law 1986 in Delaware Revlon