Illinois Appellate Court
Civil Court
Corporations
(Court opinion corrected 3/28/12.) Shareholder derivative suit alleged breach of fiduciary duty, unjust enrichment, gross mismanagement, and waste of corporate assets against consulting group (a Delaware corporation) and its directors and executives. Court properly dismissed complaint, as Plaintiff failed to adequately allege particularized facts showing that demand on directors would have been futile under Delaware Chancery Court Rule. The demand requirement for shareholder derivative suits is a substantive determination which reallocates governing powers within corporation. (QUINN and HARRIS, concurring.)