In In re Cornerstone Therapeutics Stockholder Litigation, No. 564, 2014, and In re Zhongpin Stockholders Litigation, No. 706, 2014 (collectively, Cornerstone), a consolidated appeal, the Delaware Supreme Court clarified that if an exculpatory charter provision protects directors, the trial court should grant motions to dismiss by any director against whom a plaintiff cannot plead a non-exculpated claim. As explained below, while the decision should provide comfort to independent directors, controlling stockholders or conflicted directors against whom a plaintiff can plead a duty of loyalty claim are not affected by the Cornerstone decision.