In re Tri-Star Pictures, Inc., Litig
In In re Tri-Star Pictures, Inc., Litig., 634 A.2d 319, 330 (Del. 1993), the plaintiffs alleged that the controlling shareholder took newly issued shares in exchange for fraudulently inflated property of a far lesser value, thus appreciably reducing the cash-out value of the minority shareholders' interests. This cash value dilution increased the value of the controlling shareholder's interest at the expense of the interests of the minority shareholders. Id.
The court found that the Tri-Star Pictures plaintiffs suffered harm through the corresponding dilution of their voting power. 634 A.2d at 330-32.