LAW.coLAW.co

Yanan Sun v. Wei Mig Chang

2026-07-02

Authorities cited

Opinion

majority opinion

COURT OF CHANCERY

OF THE

STATE OF DELAWARE

LOREN MITCHELL LEONARD L. WILLIAMS JUSTICE CENTER MAGISTRATE IN CHANCERY 500 NORTH KING STREET, SUITE 11400

WILMINGTON, DE 19801-3734

Date Submitted: March 17, 2026

Final Report: July 2, 2026

John G. Day, Esquire David L. Finger, Esquire

Caneel Radinson-Blasucci, Esquire 1201 N. Orange Street, 7th Floor

Prickett, Jones & Elliot, P.A. Wilmington, DE 19801

1310 N. King Street

Wilmington, DE 19801

RE: Yanan Sun v. Wei Ming Chang, et al.,

C.A. No. 2025-1228-LM

Dear Counsel,

This action concerns the composition of the board of directors of Marbella

Delaware. Plaintiff Yanan Sun and Defendant Wei Ming Chang are the Company’s

co-founders, stockholders, and directors. Their personal and business relationships

deteriorated, giving rise to a broader dispute concerning the control of the Company.

At the center of that dispute is Yong Song, a business associate of the Company who

has been appointed as the Company’s third director.

Sun contends that Song was validly appointed to Marbella Delaware’s board

through corporate actions taken in 2023 and later reaffirmed in 2024. Chang

disagrees. He argues that the steps taken to appoint Song failed to satisfy Delaware law and the Corporation’s governing documents. Chang further argues that Song’s

appointment arose from a relationship between Sun and Song, which Sun allegedly

failed to disclose before the parties executed the relevant agreements. Sun

commenced this action pursuant to Sections 205 and 225 of the Delaware General

Corporation Law (“DGCL”), seeking a declaration that Song was validly appointed

as a director of Marbella Delaware.

The Court concludes that Song was validly appointed as a director of Marbella

Delaware. The record demonstrates that Chang and Sun agreed to add Song to the

board, executed the relevant documents implementing that decision, and

subsequently treated Song as a director. Chang failed to establish that any alleged

nondisclosure rendered the challenged corporate actions invalid. Accordingly,

judgment is entered in Sun’s favor.

This is my Final Report.

I. FACTUAL BACKGROUND

A. Marbella Delaware and Its Founders

The parties operate a vacation-rental management business serving property

owners primarily in California, Washington, Colorado, and Hawaii. 1 They operate

several entities under the name Marbella Lane. Wei Ming Chang (“Defendant”) and

1

Docket Item (“D.I.”) 1 at 2–3; D.I. 48 at 3.

2

Yanan Sun (“Plaintiff”) founded the business together in 2018 when they were

married, and spent several years building it into a growing property-management

platform.2

In 2022, Plaintiff and Defendant reorganized Marbella Lane’s corporate

structure (the “Restructuring”). 3 As part of the Restructuring, they formed Marbella

Lane Holdings, Inc. and Marbella Lane (DE), Inc. (collectively, “Marbella

Delaware” or the “Company”).4 Plaintiff and Defendant are the sole stockholders

of Marbella Lane Holdings, Inc. each holding a fifty-percent ownership interest.5

Marbella Lane Holdings, Inc. wholly owns Marbella Lane (DE), Inc., which serves

as the sole member of Marbella Lane LLC, the principal operating entity through

which Marbella Lane conducts its business in California.6 Although Marbella Lane

operates through multiple affiliated entities, this dispute concerns Marbella

Delaware because it is the entity whose board of directors allegedly appointed Song

and whose corporate governance is at issue in this action.

2

D.I. 48 at 3.

3

Id.

4

Id.

5

Id.

6

Id.

3

Although Chang and Sun were married, their personal relationship

deteriorated, and they have been separated since November 2022. 7 Their separation

did not immediately alter the Company’s governance structure or day-to-day

operations. Instead, both founders continued participating in management while

attempting to grow the business and address their ongoing financial challenges. As

Marbella Delaware’s need for capital and stability increased, so too did its reliance

on Yong Song, one of the Company’s property-owner clients, and an investor.8

B. Song’s Expanding Role in the Business

Song became increasingly important to Marbella Delaware during 2022 and

2023. 9 He owned multiple properties managed through the Marbella Delaware

platform.10 Marbella Delaware also depended on Song for financial support.11

Between late 2022 and early 2024, Song loaned substantial sums to the business

while it navigated periods of financial strain.12 By 2023, Song communicated

regularly with Plaintiff and Defendant regarding Marbella Delaware’s operations,

personnel matters, and initiatives.13 As Marbella Delaware’s financial pressures

7

D.I. 48 at 8.

8

Id. at 3–4.

9

Id. at 4, 6–7.

10

D.I. 1 at 5–6.

11

D.I. 63 at 8–9.

12

D.I. 49 at 4–5.

13

D.I. 48 at 6–8; D.I. 63 at 9–10.

4

persisted and disagreements between the founders increased, Plaintiff and Defendant

began discussing a more formal role for Song within the Company.14 By Spring of

2023, both founders viewed Song as someone capable of contributing to Marbella

Delaware beyond the role of customer and lender.15

C. The Parties’ Decision to Formalize Song’s Role

In May 2023, a human resources contractor retained by the Company

recommended, amongst other things, to have a third person added as a director in an

effort to resolve some of the business conflicts between the parties. 16 The parties

agreed that Song would be the third party to assist the Company. 17

In June 2023, documents were circulated formalizing Song’s anticipated

relationship with Marbella Delaware, including materials relating to his proposed

appointment to the Board and a contemplated 10% equity grant. 18 The grant was

conditioned on a Section 409A valuation because Company counsel advised that

such a valuation was necessary to ensure the options were granted at fair market

value.19 Defendant acknowledged signing the Director Agreement (“Director

14

See Trial Tr. at 11–12 (Sun) (“And at that time [May 2023], because of the conflicts Willy and I had, the company cannot run properly.”); JX 6.0006–.0024.

15

See Trial Tr. at 9–11; JX 6.0006.

16

See Trial Tr. at 10; JX 5.

17

See Trial Tr. at 10; JX 5.

18

See JX 6.0004; D.I. 48 at 3–4.

19

See JX 6.0002.

5

Agreement” or “Agreement”) and the written-consent materials relating to Song’s

appointment. Defendant did not dispute that counsel prepared and circulated

documents to implement that Agreement. Subsequently, the parties continued to

discuss the terms of that grant through late 2023 and into early 2024, including

Song’s request that the options be issued in his son’s name. 20 Counsel later

circulated an updated Director Agreement reflecting those discussions. 21

D. Marbella Delaware’s Documents Concerning the Board of

Directors

Marbella Delaware’s Bylaws (the “Bylaws”) authorized stockholders to elect

directors, act by written consent, and fill newly created directorships. For the

purposes of the analysis, several provisions are relevant to Song’s purported

appointment.

i. Section 8(a) of the Bylaws defines “Requisite Holders” as Plaintiff and

Defendant.22

ii. Section 8(b) of the Bylaws provides:

“Except as otherwise provided by statute, the Certificate of

Incorporation or these Bylaws, directors will be elected by a

plurality of the votes of the shares present in person, by remote

communication, if applicable, or represented by proxy duly

authorized at the meeting and entitled to vote generally on the

20

JX 61.0001–.0018.

21

Id.

22

See JX 14.0005.

6

election of directors, which must at all times include the

affirmative vote of the Requisite Holders.”23

iii. Section 13(a) of the Bylaws provides:

Unless otherwise provided in the Certificate of Incorporation, any

action required by statute to be taken at any annual or special

meeting of the stockholders, or any action that may be taken at any

annual or special meeting of the stockholders, may be taken without

a meeting, without prior notice and without a vote, if a consent or

consents setting forth the action so taken, will be signed the holders

of outstanding stock having not less than the minimum number of

votes that would be necessary to authorize or take such action at a

meeting at which all shares entitled to vote thereon were present

and voted.24

iv. Section 15 of the Bylaws provides: “The authorized number of directors of

the corporation will be fixed by the Board of Directors from time to time.”25

v. Section 18(a) of the Bylaws provides:

“any vacancies on the Board of Directors resulting from . . . any newly

created directorships resulting from any increase in the number of

directors will, unless the Board of Directors determines by resolution

that any such vacancies or newly created directorships will be filled by

stockholders, be filled only by the affirmative vote of a majority of the

directors then in office.” 26

These provisions supplied the framework through which Marbella Delaware

could add a third director to its board. In particular, the Bylaws authorized

23

JX 14.0005.

24

JX 14.0007.

25

JX 14.0008.

26

JX 14.0009.

7

stockholders to act by Written Consent (“Written Consent”) and established the

procedures for filling newly created directorships.

E. The Relationship Unravels

Although separated since 2022, the parties continued working together after

the execution of the June 2023 documents. 27 During that period, Song remained

involved in Marbella Delaware’s affairs. The present dispute emerged after the

founders’ personal and business relationships deteriorated in 2024. In October 2024,

Defendant engaged a family law attorney to initiate divorce proceedings, and

disagreements concerning the Company control became intertwined with disputes

arising from the separation. 28

Although Song had been serving as a director, Marbella’s counsel was unable

to locate the executed 2023 Written Consent memorializing his appointment.29

When counsel attempted to cure the missing paperwork by preparing a replacement

consent, Defendant refused to execute it.30 Shortly thereafter, at the October 29

Board meeting, Defendant—accompanied by separate counsel—took the position

for the first time that Song had not been validly appointed to the Board. 31

27

D.I. 48 at 8.

28

D.I. 63 at 9.

29

Id. at 9.

30

Id.

31

D.I. 63 at 9.

8

The conflict intensified after Defendant initiated divorce proceedings in

California on January 6, 2025.32 Within months, Defendant expanded the dispute to

a separate California lawsuit against Plaintiff and Song, alleging fiduciary

misconduct and conversion, seeking restitution, an accounting, and declaratory

relief. 33 Defendant eventually took the position that Song had never been validly

appointed as a director and had no enforceable right to equity compensation.

Sun commenced this action shortly thereafter seeking declarations concerning

Song’s status as a director and the validity of the challenged corporate actions.

II. PROCEDURAL HISTORY

Plaintiff commenced this action on October 24, 2025. 34 The Complaint

asserts three counts seeking: (i) a determination under 8 Del. C. § 225 that Song is a

director of Marbella Delaware; (ii) alternatively, validation under 8 Del. C. § 205 of

Song’s appointment as a director; and (iii) a declaration under 8 Del. C. § 205

regarding Song’s right to acquire Marbella Delaware stock under the alleged Option

Grant. Trial was held on March 17, 2026, after which the matter was taken under

advisement. 35

32

Id.

33

Id. at 9–10.

34

See D.I. 1.

35

See D.I. 68.

9

III. ANALYSIS

For the purposes of the analysis, the Court is mindful that portions of the

testimony and briefing addressed the nature of the personal relationship between

Plaintiff and Mr. Song and whether that relationship became romantic, when it

allegedly began, and the extent to which it affected interactions among the parties.

While the Court acknowledges that those matters are significant to the parties,

personally, and may bear on disputes being litigated in other forums, they are not the

true questions presented here. This proceeding arises under Sections 205 and 225

of the DGCL and concerns a narrow issue: whether Marbella Delaware validly

appointed Song as a director under its governing documents and Delaware law.

The Court declines to undertake a broader examination of the parties’ intimate

relationships or to resolve competing factual narratives concerning their personal

lives except to the extent necessary to address the legal issues properly before it.

The Court’s analysis focuses on objective evidence of corporate action, including

the governing documents, the written consents, the Director Agreement, and

contemporaneous conduct. With those principles in mind, the Court reviewed the

record to determine whether Song validly holds office as a director.

A. Legal Standard

The DGCL Code Title 8 §225(a), empowers the Court of Chancery, “upon

application of any stockholder or director…[to] hear and determine the validity of

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any election, appointment, removal or resignation of any director or officer of any

corporation.”36 In a §225 proceeding, the plaintiff bears the burden of proving

entitlement to relief by a preponderance of the evidence. 37

A §225 action is a summary proceeding limited to issues that pertain to the

validity of corporate actions to elect or remove a director or officer.38 The Court’s

inquiry is confined to resolving disputes over who rightfully holds corporate office

and does not extend to collateral issues unrelated to the validity of the election or

appointment at issue.39 The Court focuses on whether the corporate acts at issue

complied with the Corporation’s governing documents and Delaware law.

To resolve this dispute, the Court examines the governing documents, the

Certificate of Incorporation and Bylaws, using traditional principles of contract

interpretation. 40 If the terms are clear and unambiguous, the Court will give effect

to its plain meaning.41 The Court construes the instrument as a whole, giving effect

36

See 8 Del. C. §225(a).

37

See In re IAC/InterActive Corp., 948 A.2d 471, 493 (Del. Ch. 2008).

38

See Genger v. TR Invs., LLC, 26 A.3d 180, 199 (Del. 2011).

39

See id.

40

See Matulich v. Aegis Commc’ns Grp., Inc., 942 A.2d 596, 600 (Del. 2008).

41

See Sanders v. Wang, 1999 WL 1044880, at *6 (Del. Ch. Nov. 8, 1999).

11

to all provisions and seeking to ascertain the parties’ intent from the four corners of

the document.42

Similarly, the DGCL provides that “the business and affairs of every

corporation organized shall be managed by or under the direction of a board of

directors, except as may be otherwise provided in this chapter or in its certificate of

incorporation.”43 “[U]nless otherwise provided in the certificate of incorporation or

bylaws, vacancies and newly created directorships . . . may be filled by a majority

of the directors then in office.”44 A board of directors can take action at a meeting

or through unanimous action by written consent without a meeting.45

Finally, when determining the validity of a challenged corporate act, the Court

may consider not only the formal corporate instruments themselves but also the

parties’ contemporaneous and subsequent conduct insofar as that conduct sheds light

on their understanding of, assent to, and implementation of the challenged action.46

42

See GMG Capital Invs., LLC v. Athenian Venture Partners I, L.P., 36 A.3d 776, 779 (Del. 2012).

43

See 8 Del. C. §141(a).

44

8 Del. C. §223(a)(1).

45

See 8 Del. C. §141(b); see also 8 Del. C. §141(f).

46

See Matulich, 942 A.2d at 600.

12

B. Defendant Has Not Established a Basis to Invalidate the Director

Agreement

Plaintiff contends the Director Agreement validly appointed Song to Marbella

Delaware’s board of directors and remains enforceable. 47 Defendant argues the

Director Agreement is void because Plaintiff allegedly failed to disclose an intimate

relationship with Song before execution and further contends that Song’s

appointment diminished Defendant’s influence during a period of turmoil.48

According to Defendant, had he known the nature of Plaintiff’s relationship with

Song and the extent of Song’s alleged lack of neutrality, he would not have executed

the Director Agreement.49 Defendant advances a fiduciary duty to disclose theory

based on marital and corporate roles, maintaining that Plaintiff, as both a director

and his spouse, owed a fiduciary duty to disclose the relationship before execution

of the agreement.50

§ 225 concerns the validity of the challenged corporate act. It is not a vehicle

to litigate every grievance that may exist between the parties.51 “A Section 225

action is an improper vehicle for trying purely collateral issues, issues of director

47

See D.I. 48 at 12.

48

See D.I. 49 at 11.

49

See id. at 11–12.

50

See id.

51

See Genger, 26 A.3d at 199.

13

misconduct or other breaches of fiduciary duty. A claim is ‘purely collateral’ if

resolution of the claim does not help the Court decide the proper composition of the

board of directors or management team or the validity of a stockholder vote.”52

Accordingly, the primary inquiry is whether Marbella Delaware validly appointed

Song as a director consistent with corporate law and corporate formalities.

Defendant identifies no Delaware authority holding that failure to disclose a

personal or romantic relationship renders an otherwise valid director appointment

void. Nor has Defendant identified any provision of Marbella Delaware’s governing

documents or the Director Agreement requiring disclosure of such a fiduciary

relationship as a condition precedent to Song’s appointment. Defendant’s own

authorities confirm the limits of his argument. Defendant relies on Gaffin v.

Teledyne, Inc. for elements of equitable fraud and In re Wayport, Inc. Litigation

regarding the need for a special relationship, but even assuming a special

relationship, Defendant must prove a material omission, justifiable reliance,

causation, and an appropriate remedy for the resulting damages.53 He did not.

The alleged omission was not made a representation, warranty, or condition

of Song’s appointment in the governing documents or the Director Agreement.

52

Nazarian v. Sassouni, 2025 WL 1913182, at *7 (Del. Ch. July 11, 2025) (internal citations omitted).

53

611 A.2d 467 (Del. 1992); 76 A.3d 296, 327 (Del. Ch. 2013).

14

Defendant identifies no provision of the Director Agreement, the certificate of

incorporation, the bylaws, or the DGCL that conditioned Song’s appointment on

disclosure of Plaintiff’s personal relationship with Song. Without that link, on this

record, the alleged omission does not establish that the corporate act itself was

invalid.

Defendant’s marital fiduciary-duty authorities are also distinguishable.

Defendant in his briefs cites Angelli v. Sherway, Peyton v. William C. Peyton Corp.,

and California Family Code § 721 to argue that Plaintiff owed duties to Defendant

as a spouse. 54 Those authorities may speak to duties between spouses in an

appropriate domestic-relations or fiduciary-duty case. However, they do not hold

that an alleged failure to disclose a personal relationship automatically voids a

Delaware corporate appointment. Whatever claims Defendant may wish to pursue

arising from the parties’ personal relationship are beyond the limited scope of this §

225 proceeding, which concerns only whether the challenged corporate act was

validly taken.

“When addressing a claim to corporate office under § 225, the Court may

consider whether the claim is tainted by fraud, deceit or breach of contract. But that

determination may be made ‘only for the purpose of determining the corporation’s

de jure directors and officers,’ not for the purpose of assessing in personam liability

54

See D.I 49; D.I. 65; 560 A.2d 1028 (Del. 1989); 7 A.2d 737 (Del. 1939).

15

for actionable wrongdoing.”55 The Court therefore need not determine whether

Plaintiff and Song in fact maintained an intimate physical relationship during the

relevant period. The dispositive question is not the nature of Plaintiff’s personal

relationship with Song, but whether Marbella Delaware complied with the corporate

formalities necessary to appoint Song as a director.

Defendant’s rescission cases are likewise distinguishable. Defendant

highlights Sabbarese v. Sabbarese, and Brown v. Brown, which involved domestic

agreements where concealment of adultery allegedly affected rights arising from the

marital relationship itself. 56 However, those cases do not involve the appointment

of a corporate director under Delaware law. Defendant likewise cites Sheehan v.

Hepburn, and Russell v. Universal Homes, Inc., for the general availability of

equitable rescission where legal remedies are inadequate.57 Those cases do not

relieve Defendant of proving fraud, justifiable reliance, and a defect that warrants

unwinding the Director Agreement.

Even assuming that Plaintiff had a duty to disclose, the record does not

establish justifiable reliance. To prevail on a claim of equitable fraud, a party must

55

Zhou v. Deng, 2022 WL 1024809, at *4 (Del. Ch. Apr. 6, 2022), aff’d, 287 A.3d 633 (Del. 2022).

56

D.I 49; 146 A. 592 (N.J. Ch. 1929); 2013 WL 12180656 (Tenn. App. Sept. 12, 2013). 57

138 A.2d 810 (Del. Ch. 1958); 1991 WL 94357 (Del. Ch. May 23, 1991).

16

establish justifiable reliance on the alleged misrepresentation or omission.58

Defendant suspected Plaintiff and Song maintained a relationship beyond an

ordinary business association before executing the Director Agreement.59

Defendant’s own testimony reveals that he proceeded with the transaction despite

concerns regarding Plaintiff’s relationship with Song. Defendant has not established

that the alleged omission rendered the Director Agreement invalid or otherwise

affected the legal effectiveness of Song’s appointment. The Court, therefore, rejects

Defendant’s challenge to the validity of the Director Agreement on that basis.

C. The Record Establishes that the Director Agreement was Validly

Formed

The validity of the Director Agreement also turns on whether the parties

complied with the governing documents and applicable law in appointing Song to

the board. Under the certificate of incorporation and Bylaws, stockholders elect

directors through a vote at an annual meeting or through written consent. 60 The

Bylaws provide that stockholder actions may be “taken without a meeting, without

prior notice and without a vote, if a consent or consents setting forth the action so

taken, will be signed by the holders of outstanding stock having not less than the

minimum number of votes that would be necessary to authorize or take such

58

See Gaffin v. Teledyne, Inc., 611 A.2d 467, 472 (Del. 1992).

59

JX 128.0001–.0002; Trial Tr. 96.

60

See JX 21.0002; JX 14.0005.

17

action.”61 The board can fix the number of directors and the board can fill a vacancy

created by a newly created directorship.62

The evidence shows that the parties undertook precisely those steps. Plaintiff

and Defendant were Marbella Delaware’s sole stockholders and directors at the

relevant time.63 Defendant asked the Company counsel about adding Song to the

board.64 Counsel responded by preparing the appropriate corporate documents

designed to effectuate Song’s appointment. 65 Those documents included a Written

Consent appointing Song as a director and a Director Agreement defining Song’s

role with the Company.66 The Written Consent is particularly significant because

Marbella Delaware’s Bylaws expressly authorized stockholders to act by Written

Consent in lieu of a meeting. Thus, if properly executed, the Written Consent

constituted a legally sufficient mechanism for electing Song as a director.

The record further reflects a consistent course of conduct supporting the

conclusion that Song’s appointment was the product of a negotiated business

arrangement and was understood by the parties as such. The Company’s finances

61

JX 14 at §13(a).

62

Id. §15, 18.

63

See generally JX 14; JX 21.

64

See JX 6.0006.

65

See JX 6.0004–.0006; JX 46.

66

See JX 28; JX 30.

18

depended on Song’s loans; 67 internal communications identified Song as a director

with a contemplated 10% equity interest and as a board member; 68 and decision

making within the Corporation had reached an impasse between the two existing

principals leading to Song’s involvement to be tied to stabilizing the Company’s

operations.69 This context is significant because it demonstrates that Song’s

appointment was not a spontaneous or unexplained corporate act. Rather, the

appointment emerged from months of discussions concerning Song’s growing role

in the business and the founders’ efforts to address operational and governance

challenges.

In response to Defendant’s inquiry regarding Song’s holdings, Company

counsel provided a capitalization promise reflecting that Song would hold a 10%

ownership interest in Marbella Delaware. 70 Defendant did not object to this

allocation.71 Defendant also initiated the discussion of Song’s board participation.72

These communications reflected a record of shared understanding that Song would

receive both an ownership interest and a governance role. Consistent with that

67

See D.I. 49 at 8. Defendant states “[g]iven the company’s financial condition at the time, [the Corporation] depended heavily on those loans to continue operating.” 68

See D.I. 48 at 4; see also JX 49.

69

See JX 6.0006–.0024.

70

See JX 48.

71

See JX 49.

72

See JX 6.0006.

19

understanding, internal Company communications identified Song as a member of

the board alongside Defendant and Plaintiff. 73

Importantly, Defendant actively participated in Song’s appointment.

Defendant concedes that he signed both the Director Agreement and Written

Consent in June 2023. 74 Defendant identified no defect in the execution of those

documents and did not contend that the Written Consent failed to satisfy the

requirements of the Bylaws. Instead, Defendant’s current challenge rest primarily

on the assertion that he should not have agreed to Song’s appointment in the first

place. 75 The record reflects Defendant’s approval of Song’s appointment and

participation in the corporate actions necessary to effectuate it. The Director

Agreement and Written Consent were treated as operative corporate documents, and

the record contained no contemporaneous objection to Song’s appointment or status

as a director. Taken together, Marbella Delaware validly exercised its authority to

appoint Song as a director in June 2023.

D. The Director Agreement was Treated as Valid and Enforceable

The record does not reflect any effort by Defendant to challenge or revoke

Song’s status while he acted as Director. At trial, Defendant criticized Song’s

73

See JX 55 (“The board of Marbella Lane consists of three members: Willy Chang, Yanan Sun, and [Yong] Andrew Song.”).

74

See JX 121.

75

See D.I. 49 at 8; Trial Tr. 9–10.

20

attendance at board meetings, performance as a director, and alleged misconduct

related to purported financial fraud. 76 However, these contentions are collateral to

the limited § 225 inquiry and do not bear on whether his appointment was validly

affected. Even if the Court accepted Defendant’s criticisms of Song’s performance,

those criticisms would not establish that Song failed to become a director or ceased

to be one.

An updated Director Agreement was executed by the parties effective April

2024. 77 The execution of a revised Director Agreement nearly ten months after

Song’s appointment is inconsistent with Defendant’s current contention that Song

never validly joined the board. The updated Agreement is persuasive because it was

executed after months of experience working with Song in his director capacity.

Defendant and Plaintiff had been separated since November 2022, and the

Director Agreement and accompanying written consents were executed during that

period of separation in 2023 and 2024. To the extent Defendant relies on the alleged

relationship to challenge the validity of the Director Agreement, those arguments

arise from circumstances that developed after the execution of the Agreement and

are intertwined with the subsequent deterioration of the parties’ personal and

professional relationship. Viewed as a whole, the post-execution record confirms

76

See Trial Tr. 2–6.

77

JX 69.

21

that the parties treated Song as a duly appointed director of Marbella Delaware,

supporting the validity of the June 2023 corporate action.

E. Alternative Relief Under Section 205

Plaintiff also seeks alternative relief under 8 Del. C. § 205. § 205 authorizes

the Court to validate defective corporate acts under appropriate circumstances.

Because the Court concludes that Marbella Delaware validly appointed Song as a

director in the first instance, no validation is necessary under § 205, and the Court

does not reach the alternative request, including the alleged Option Grant. The Court

declines to reach Plaintiff’s alternative § 205 claim given the § 225 determination.

IV. CONCLUSION

For the foregoing reasons, the Court concludes that Song was validly

appointed as a director of Marbella Delaware. The evidence supports that the parties

complied with the Corporation’s governing documents to form a valid Director

Agreement, treated Song as a member of the board, and that Defendant has not

established grounds to invalidate the Agreement. Accordingly, the Court finds in

favor of Plaintiff.

This is my Final Report. Any exceptions to this Report shall be filed within

three days.

22

If no exceptions are taken, the Plaintiff shall submit an implementing order

consistent with this decision within one week thereafter.

Respectfully submitted,

/s/ Loren Mitchell

Magistrate in Chancery

23