Hedge fund managers are increasingly turning to a long-underused litigation-based mechanism to generate investment returns. That mechanism – the Delaware stockholder appraisal action – allows managers controlling shares in a company targeted for merger or consolidation to significantly increase the value of those shares through a pure litigation play. In a guest article, Ben Quarmby and Hassan A. Shah, a partner and an associate, respectively, at MoloLamken, review how appraisal actions work and describe some recent results. The article then discusses the advantages of using appraisal over traditional stockholder litigation, as well as some recent legislative and judicial pushback. Finally, the authors consider the potential opportunity that shareholder appraisal actions present for hedge fund managers and other asset managers. For additional insight from Quarmby, see “Measures Hedge Fund Managers Can Implement to Maximize Protection of Their Trade Secrets” (Dec. 6, 2012). For commentary from other MoloLamken practitioners, see “FCPA Considerations for the Private Fund Industry: An Interview With Former Federal Prosecutor Justin Shur” (May 23, 2014); “How Private Fund Managers Can Manage FCPA Risks When Investing in Emerging Markets” (Jan. 10, 2013); and “Political Intelligence Firms and the STOCK Act: How Hedge Fund Managers Can Avoid Potential Pitfalls” (Apr. 5, 2012).