Law360, New York ( May 31, 2013, 5:43 PM EDT) -- In a recent decision, the Delaware Court of Chancery held that the plaintiff had demonstrated a reasonable likelihood that the single-bidder sale process undertaken by the target's board of directors did not satisfy the board's duties to maximize stockholder value, i.e., its Revlon duties. In Koehler v. NetSpend Holdings Inc.,[1] Vice Chancellor Sam Glasscock expressly endorsed the permissibility of single-bidder processes in sale of control transactions, but found that the remainder of the sale process resulted in the board's failure to adequately inform itself as to whether the price per share in the merger was the highest price reasonably available....