Sandys ex rel. Zynga Inc. v. Pincus

In the context of derivative litigation, directors are presumed to be disinterested and independent. However, certain relationships of venture directors are complicated by the fact of their multiple cross-holdings. While having a venture investor as a board member can be valuable because of the insight and experience they might bring to the table, it can also be complicated by the web of connections that can called into question their disinterestedness.