In Freund v. Lucent, Pomerantz was among the first firms to use the Delaware “books and records” statute, 8 Del. C. §220, to obtain documents from the company before filing a derivative action. See Freund v. Lucent Techs., Inc., No. Civ. A. 18893, 2003 Del. Ch. LEXIS 3 (Del. Ch. Jan. 9, 2003). This allowed us ultimately to file a much more specific derivative complaint that withstood a motion to dismiss.