triggered "where a majority of the directors approving the transaction were interested or where a majority stockholder stands on both sides of the transaction." Directors can be found to be interested if they "appear on both sides of a transaction [or] expect to derive any personal financial benefit from it in the sense of self-dealing, as opposed to a benefit which devolves upon the corporation or all stockholders generally." Once the entire fairness standard is triggered, the corporate board has the burden to demonstrate that the transaction was inherently fair to the shareholders, by both demonstrating fair dealing (i.e., process) and fair price (i.e., substance). Subsequent debate Subsequent cases such as Paramount v. Time (the Time Warner case) and Paramount v. QVC addressed when a board assumes the Revlon duty to auction the company and forego defensive measures that would otherwise be permissible under Unocal. Expanding the scope of the intermediate enhanced scrutiny standard of judicial review previously announce in Unocal and Moran v. Household International, Inc., the Revlon opinion gave rise to years of academic debate and decisional law with respect to the events that should be deemed to trigger its application. Even today, questions continue to persist as to the extent to which the doctrine has been absorbed into the traditional duty of care, particularly in connection with so-called ownership transactions such as mergers, and its interplay with the Unocal test traditionally applicable to defensive board action to fend off a hostile acquisition bid, and more recently to deal protection devices contained in merger agreements. See Omnicare v. NCS Healthcare, Inc. 818 A.2d 914 (Del. 2003); compare, e.g., In re Netsmart Technologies, Inc. Shareholders Litigation, 924 A.2d 171 (Del. Ch. 2007). Despite the expanse of precedent that Revlon has engendered in the more than 20 years since its issuance, the Revlon doctrine remains alive, well and surprisingly vague in terms of its scope and its application. Far more certain, however, is the likelihood that as a result of the principles enunciated by the Revlon decision, practitioners can be assured that cash mergers and change of control transactions will engender far closer judicial scrutiny than the broad judicial deference that had been previously regarded as typical and appropriate, as will a board's approval of provisions in merger agreements that unduly restrict the board's ability to entertain more lucrative offers that appear between signing of the merger agreement and its