A sample complaint that a plaintiff may use to commence a shareholder derivative action in the Delaware Court of Chancery. This Standard Document contains integrated drafting notes with important explanations and tips for drafting the complaint's caption, preliminary statement, jurisdiction, and fact sections. This Standard Document also sets out allegations required for a derivative action under Delaware law, such as the derivative plaintiff's standing to sue, demand futility and wrongful demand refusal and contains drafting notes with important explanations and tips for drafting the legal claims, prayer for relief, and signature block.