Partner Gardner Davis was quoted in a September 12, 2013 article in Thomson Reuters titled “Delaware high court says fraud exemption can’t revive Countrywide suit.” The article discusses how Bank of America Corp. can’t use Delaware’s “fraud exemption” to revive their derivative suit against its officers. Mr. Davis was quoted saying, “I think this case will be remembered for its discussion of the viability of a direct shareholder cause of action for fraud in the post-merger context.”