DANIEL JAIYONG AN V. ARCHBLOCK, INC

On June 29, 2023, the holders of a majority of the issued and outstanding shares of the Company's stock acted by written consent to approve the adoption of an Agreement and Plan of Merger through which the Company would change its domicile from Delaware to Switzerland (the "Redomestication Transaction"). The Individual Defendants breached their duties by approving the merger agreement to benefit themselves and without any justification. The Individual Defendants failed to follow any of the prescribed rules under Delaware law, the Company's Certificate of Incorporation, or the Company's Bylaws for the approval of such a merger in a rush to enrich themselves." "To inspect books and records under Section 220, a plaintiff must establish by a preponderance of the evidence that the plaintiff is a stockholder, has complied with the statutory form and manner requirements for making a demand, and has a proper purpose for conducting the inspection."