The article discusses how Delaware laws on controlling shareholders have changed over time, leading to inconsistencies in how their actions are approved by directors. Recent court decisions have made it crucial to determine if a transaction involves a controlling shareholder, as this can decide the outcome of shareholder disputes. However, identifying controlling shareholders has become harder due to complex business structures. The article suggests that courts should focus on the unique power controlling shareholders have and consider the lack of market discipline they face when evaluating their actions.