Business Law

Business Law 2021: Athlon and the Death of the Delaware Block Method


For many years, trial courts around the country (including in Tennessee) relied exclusively or principally on a judicially constructed process for engaging in appraisal valuations under state corporate dissenters’ rights statutes. That process is known as the “Delaware Block” (or “weighted average”) method. In 1983, the Delaware Supreme Court abandoned the exclusive use of the Delaware Block method for appraisal valuations undertaken under Delaware law, adopting “a more liberal approach” that determines value through the use of “any techniques or methods which are generally considered acceptable in the financial community.” Although it took 35 years, the Tennessee Supreme Court also rejected the exclusive use of the Delaware Block method for appraisal valuations in 2018. This panel unpacks the modern history of appraisal valuations in Tennessee from a legal and financial perspective and offers counsel advice on how to navigate appraisal litigation using financial valuation experts.


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Course Pricing
  • Member: 45.00
  • Non-Member: 75.00
  • Section: 35.00
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Course InformationHighlights
  • Approved Distance Learning
  • Convenient CLE from your home or office!
  • Viewable from your laptop or mobile device
  • All 2021 CLEs can be taken online
Course Credits Dual Credits: 0.00
General Credits: 1.00
Total Credits: 1

This program will be filed for Tennessee CLE credit. Please email a request to for Georgia and Mississippi CLE credit.