Google aims to insulate its executives somewhat from shareholder demands.
Insurance carriers and managed-care companies are driven by fiscal concerns and shareholder demands for profitability, not by ethical standards.
The court ruling is expected to prolong the fight over ABN Amro and could put more pressure on directors to listen to shareholder demands.
And the minority public stake gave the hybrid some insulation from shareholder demands for performance that pure stock companies faced.
Specifically, they were interested in the circumstances in which a board could resist shareholder demands to fire the chief because of disappointing performance.
Rather than forcing an all-or-nothing showdown, boards should respond to shareholder demands to end staggering with the counter-offer of a bylaws-based staggered board.
In late March, the company said it would comply with the shareholder demands, but the board did not formally meet to consider the changes until April 6.
Mr. Barbakow said Tuesday that he would step down as chairman and director, but remain chief executive, to satisfy shareholder demand for a stronger board.
Open-end mutual funds trade at their net asset value, with the number of shares on the market expanding or contracting with shareholder demand.
Thursday's ruling could put more pressure on the boards of companies to listen to shareholder demands.