The Delaware Court of Chancery recently decided In re eBay, Inc. S’holders Litig., No. 19988-NC, 2004 Del. Ch. LEXIS 4 (Del. Ch. Jan. 23, 2004) on the alleged practice of "spinning" IPO shares. The case is notable both because of its strong language regarding the practice and because it lowers the barriers for plaintiffs to show that plaintiffs are not required to make a "demand" on the Board of Directors before filing suit.