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Delaware Court of Chancery Denies Expert Opinion Motions

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Filed February 23rd, 2026
Detected February 24th, 2026
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Summary

The Delaware Court of Chancery denied three out of four motions in limine seeking to exclude expert opinions in the In re Saama Technologies Litigation (C.A. No. 2022-1045-LWW). A decision on the fourth motion was deferred. The court found that challenges to expert methodologies and data could be addressed during cross-examination.

What changed

The Delaware Court of Chancery, in the consolidated litigation In re Saama Technologies (C.A. No. 2022-1045-LWW), denied three motions in limine seeking to exclude expert testimony and reports. The court deferred a decision on a fourth motion. The denied motions raised arguments regarding the experts' methodologies, data sources, and qualifications, including claims that opinions were generalized, relied on unverified data, or lacked industry-specific expertise. The court stated that these issues could be better assessed during cross-examination after trial, rather than prejudging them at the pre-trial stage.

This ruling means that the expert testimony in question will likely be presented at trial, with challenges to its reliability and weight to be made during cross-examination and closing arguments. Legal professionals involved in this case should prepare to address these expert opinions and their evidentiary value. The court's decision indicates a preference for allowing parties to fully explore expert deficiencies during the trial process, rather than excluding them pre-emptively, unless the deficiencies are so profound as to render the testimony unhelpful.

What to do next

  1. Prepare to address expert testimony challenges during cross-examination
  2. Assess the weight and reliability of expert opinions in light of potential challenges

Source document (simplified)

COURT OF CHA NCERY OF THE STATE OF DEL AWARE L ORI W. W I LL V ICE C HANCELLO R L EONARD L. W ILLIAMS J USTICE C ENTER 500 N. K ING S TREET, S UITE 11 400 W ILMI NG TON, D ELAWARE 19801-373 4 February 23, 2026 A. Thompson Baylis s, Esq. Eric A. Ve res, Esq. Clara E. Hubbard, Esq. Abrams & B ayliss LLP 20 Montcha nin Road, Suite 200 Wilmington, Delaware 19807 Daniel A. Mason, Esq. Sabrina M. Hendershot, E sq. Emily V. Cox, Esq. Paul, We iss, Rifkind, Wharton & G arrison L LP 1313 North Ma rket Street, Suite 806 Wilmington, Delaware 19801 Michael A. Pittenger, Esq. Matthew F. Davis, Esq. Megan R. Thomas, Esq. Potter Ande rson & Corroon LLP 1313 North Ma rket Street Wilmington, Delaware 19801 RE: In r e Saama Technologies Litigation, Consol. C.A. No. 2022-1045-LWW Dear C ounsel, I have reviewed the f our pending motions in limine to preclude expe rt reports or testimony in th is matter. 1 For the reas ons given below, three of the motions are denied without pre judice. A de cision on the fourth mot ion is deferred. 1 Four other pre-trial motions were addressed separately in a February 18, 2026 bench ruling. The present motions were set to be argued tomorrow, February 24, 2026, during the pre-trial conference. Oral argument is unnecessary.

C.A. No. 2022-1045-LWW February 2 3, 2026 Page 2 of 4 The parties have filed three motions seeking to exclude existing expert opinions: 1. Defendants’ Motion in Limine to Exclud e the Opinions of B rendan Ballou; 2 2. Plaintiff’s Motion in Limine to Exclude Reports and Testimony of Louis Dudney a nd Jeff Hagins regarding m argin data; 3 and 3. Plaintiff’s Motion in Limine to Exclude Expert R eport and T estimony of Jeff Hagins regarding Saa S margins and industry reputation. 4 Delaware Rule of Evidence 702 asks that I consider whether the expert’s testimony will help me as the trier of fact to understand the evidence or determine a fact in issue. 5 The motions raise various arguments regarding the expe rts ’ methodologies, data sources, and qualifications. For example, the defendants as sert that Mr. Ballou ’ s opinions regardi ng private equity incentives are generalized a nd lack a dis cernible methodology. The plaintiff argues that Mr. Dudney and Mr. Hagins rely on unverified ma rgin spreadsh eets created for litigation. And he a lso contends that M r. Hagins lacks specific expertise in the life sciences industry to properly opine on Saama ’ s business. 2 Dkts. 352, 372. Reply briefs were also filed. At the time of this decision, the replies were not yet accepted onto the docket by the Register in Chancery. 3 Dkts. 354, 371. 4 Dkts. 355, 369. 5 Del. R. Evid. 702(a).

C.A. No. 2022-1045-LWW February 2 3, 2026 Page 3 of 4 Presently, I cannot s ay whether this tes timony will be helpful to my understanding. But it might. Cons istent with my general approach to pre -trial motions in limine on expe rt r epo rts, I decline to prejudge the is sues now. The parties will have ample o pportunity to e xplore these alleged deficiencies on cros s - examination, allow ing me to bet ter asses s the experts’ positions a nd h ow they interact with other evidence. The motions a re therefore denied, without prejudice to the parties ’ ability to challenge the expert opinions a nd testimony a fter tr ial. If an expert ’ s a nalysis lacks support or reliabil ity, I will give it equall y little (or no) weight. 6 The fourth motion is the Defendants ’ Motion in Lim ine to P reclude T. Jeffrey Wilks from Of fering Undisclosed Ex pert Opinions. 7 The defendants raise concerns that Mr. Wilks intends to abandon his disclosed pos ition — that he ca nnot reach a conclusion on the proper reve nue recognitio n for the disputed contract — and ambus h them with a new ca lculation based on testimony from recently disclosed fact 6 See, e.g., Beard Rsch., Inc. v. Kates, 8 A.3d 573, 593 n.122 (Del. Ch. 2010) (declining to exclude evidence because, in a bench trial, the court can consider the testimony “in light of any flaws... that may have been exposed through cross - examination” (cit ing Trs. of Chi. Painters & Decorators Pension, Health & Welfare, & Deferred Sav. Plan Tr. Funds v. Royal Int’l Drywall & Decorating, Inc., 493 F.3d 782, 788 (7th Cir. 2007))). 7 Dkts. 350, 373.

C.A. No. 2022-1045-LWW February 2 3, 2026 Page 4 of 4 witnesse s. The plaintiff, however, insists that Mr. Wilks will not offer a new opinion at trial. I a ppreciate the defendants alerting me to this potential issue in advance of trial, but will defe r ruling on it a t this time. This motion appears to pres ent a hypothetical dispute. I decline to preclude evidenc e that may ne ver be proffered. I will add ress this iss ue if and whe n a ne w opinion is of fered a t t rial. The parties are, of course, bound by the Order Governing Expert Discovery. 8 If the plaintiff attem pts to elici t an e xpert opinio n from M r. Wilks that was not properl y disclosed during expe rt discovery, the defendants may renew their objectio n. 9 If that comes to pass, I may well be inclined to rejec t any newly off ered opinio n. IT IS SO OR DERED. I look forward to s peaking with you at to morrow’s pre - trial con ference and seeing you at trial next wee k. Sincerely you rs, /s/ Lori W. Will Lori W. Will Vice Chancellor 8 Dkt. 246. 9 Cf. Sammons v. Drs. for Emergency Servs., P.A., 913 A.2d 519, 528 (Del. 2006) (explaining, in the context of a jury tr ial, that “ [p] arties must comply with the discover y rules by identifying expert witnesses and disclosing the substance of their expected opinions as a precondition to the admissibility of expert testimony at tria l ”).

Source

Analysis generated by AI. Source diff and links are from the original.

Classification

Agency
Federal and State Courts
Filed
February 23rd, 2026
Instrument
Enforcement
Legal weight
Binding
Stage
Final
Change scope
Minor

Who this affects

Applies to
Legal professionals Courts
Geographic scope
State (Delaware)

Taxonomy

Primary area
Judicial Administration
Operational domain
Legal
Topics
Evidence Expert Testimony

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