In Bender v. Memory Metals, Inc. (514 A2d 1109, 1115 (Del Ch 1986), the court held that the act of registering a transfer "to include those ministerial acts that normally accompany such registration, including, where applicable, the issuance of a new certificate" (id.). The plaintiff in Bender was already a stockholder. She Was seeking the issuance of a new certificate for her stock, as her existing certificate contained restrictive language.