Document: City of Westland Police & Fire Retirement System v. Axcelis Technology, Inc., C.A. No. 4473-VCN, Noble, V.C. (Del. Ch. Sept. 28, 2009) 

The Court dismissed plaintiffs’ action under Section 220 of the General Corporation Law of Delaware for books and records of the defendant company, finding that the plaintiff failed to demonstrate a credible basis from which the Court could infer mismanagement, waste or wrongdoing as required to state a proper demand for books and records.  The Court specifically noted as to one of plaintiffs’ claims, that plaintiff must point to something other than a precipitous drop in stock price to be granted Section 220 inspection rights.