The Delaware Court of Chancery last week made clear that documents to be produced in connection with a valid books-and-records demand include emails and other electronically stored information.

In Amalgamated Bank v. Yahoo, Vice Chancellor J. Travis Laster ruled that a shareholder won the right to inspect the emails of a top Yahoo Inc. official related to its inquiry into the hiring and subsequent firing of Henrique de Castro, who served only 15 months as the company’s chief operating officer.