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Post-Merger Employment Agreements With Target Management And SEC Rule 14d-10: A Trap For The Unwary?

Dutka, Paul

(December 2002, Business & Securities Litigator)




By Paul Dutka and Sirin Thada

As the curtain has rung down in recent years on hostile tender offers, negotiated acquisitions have seized center stage, propelled by perceived synergies between acquiror and target.  Because the merger’s success often depends on retaining the target’s senior management, understanding the impact of Securities and Exchange Commission Rule 14d-101 (the “All-Holders, Best-Price” rule) on an acquiror’s ability to negotiate post-merger employment agreements with target management during the tender offer carries increased urgency.


Recently, in Gerber v. Computer Associates International, Inc., 303 F.3d 126 (2d Cir. Sept. 4, 2002), the Second Circuit held that the acquiror’s payment to the target’s chief executive officer under a post-merger non-compete agreement, when the CEO also owned a block of the target’s stock, violated Rule 14d-10, although the payment was made after the tender offer closed.  The Second Circuit concluded that part of the consideration the CEO received constituted unlawful additional payment for his shares, and ordered that the plaintiff class of tendering shareholders receive the same increased price for their shares.


This article focuses first on Gerber, then turns to other leading cases illustrating how the courts have split over the application of Rule 14d-10.  

The “All Holders, Best Price” Rule

In adopting Rule 14d-10 in 1986, the SEC announced that the Rule’s all-holders and best-price requirements were necessary to implement the investor protection purposes of the Williams Act.  Thus, Rule 14d-10 preclude[s] bidders from discriminating among holders of the class of securities that is the subject of the offer, either by exclusion from the offer or by payment of different consideration.  Without the all-holders and best-price requirements, the investor protection purposes of the Williams Act would not be fully achieved because tender offers could be extended to some security holders but not to others.  Such discriminatory tender offers could result in the abuses inherent in “Saturday Night Specials,” “First-Come First Served” offers and unconventional tender offers since security holders who are excluded from the offer may be pressured to sell to those in the included class in order to participate, at all, in the premium offered.  These excluded security holders would not receive the information required by the Williams Act, would have their shares taken up on a first-come first-served basis and would have no withdrawal rights.2


Rule 14d-10 states that “[n]o bidder shall make a tender offer unless: (1) the tender offer is open to all security holders of the class of securities subject to the tender offer; and (2) the consideration paid to any security holder pursuant to the tender offer is the highest consideration paid to any other security holder during such tender offer.”3
But, as Gerber illustrates, Rule 14d-10 has in turn engendered controversy because of the ambiguity attaching to the phrase “during such tender offer.”  Some courts, including the Second Circuit, use a “functional” approach, broadly interpreting the word “during” and inquiring whether additional payment made outside the tender offer period nonetheless furthered the acquiror’s goal of merging and thus violated Rule 14d-10.  Other courts have adopted a “formal” or “bright-line” approach, under which a violation of Rule 14d-10 occurs only if the additional payment is literally paid “during” the tender offer.


This split among the courts promises continuing difficulty in structuring post-merger employment agreements with target management, a difficulty which is exacerbated by the disastrous financial consequences that violations can carry because any “increased consideration” must be paid to all tendering shareholders.4  


Gerber v. Computer Associates Int’l, Inc.
In July 1991, Computer Associates’ chairman  Charles Wang approached On-Line chief executive officer Jack Berdy about acquiring On-Line.  Eventually they agreed upon the terms of a tender offer and back-end merger.  Computer Associates offered to purchase On-Line stock for $15.75 per share, and contracted to give Berdy $5 million for his agreement not to compete.5


Plaintiff Joel Gerber, an On-Line shareholder, later filed a purported class action on behalf of tendering shareholders, principally alleging that the $5 million was in reality increased consideration for Berdy’s 1.5 million On-Line shares.6  Computer Associates moved to dismiss, arguing that the non-compete agreement was made before the tender offer began, and, thus fell outside Rule 14d-10.7  The district court denied the motion, concluding as a matter of law that the tender offer had commenced five days before Berdy’s non-compete agreement was signed, when the companies issued a press release announcing the terms of the offer, subject to a number of conditions, including board and regulatory approvals and the execution of definitive agreements.8


The court then certified the plaintiff class,9 and Computer Associates moved for summary judgment.10  The court granted summary judgment in part, but denied the motion with respect to the Rule 14d-10 claim because the court found genuine issues of material fact concerning the nature and purpose of the $5 million payment to Berdy.11  The case eventually went to trial, and the district court instructed the jury to “consider whether the payment of 5 million dollars under the so-called Berdy agreement was paid to Dr. Berdy for his On-Line shares, or his agreement not to compete, or partly for the shares and partly for the agreement not to compete.”12

The jury returned a special verdict for the plaintiff class, finding that $2.34 million of the $5 million was unlawful additional payment for Berdy’s shares, while the rest was legitimate compensation for his non-compete agreement.   The court entered judgment totaling $5.67 million, representing an additional $1.46 per share of On-Line common stock for the class, plus interest.13 Computer Associates moved for judgment notwithstanding the verdict, or a new trial, which was denied.14  Computer Associates appealed.


The Appeal
On appeal, Computer Associates argued that the Rule 14d-10 claim was insufficient as a matter of law because, even if the Berdy agreement was signed during the tender offer, Berdy was not paid until five days after the tender offer had closed.  But, true to the functional approach, the Court of Appeals looked beyond the tender offer’s “self-prescribed expiration date” and rejected Computer Associates’ timing argument.  “While Rule 14d-2 governs the determination of when a tender offer commences,” reasoned the Court of Appeals, “no pertinent rule or statute addresses when a tender offer concludes.”15  Given this, “the phrase ‘during the tender offer’...is flexible enough to include [Computer Associates’] payment to Berdy....”16


In reaching this conclusion, the Court emphasized that Computer Associates paid Berdy before paying any other shareholders, so “if Berdy was not paid ‘during the tender offer,’ then neither was any other On-Line shareholder.”17  Taking a bright-line approach and simply equating the end of the tender offer with its self-proclaimed expiration date “would make it all too easy to contract around the Best Price Rule” and would render the rule “toothless.”18


The Court relied on its earlier decision in Field v. Trump, 850 F.2d 938 (2d Cir. 1988), where defendants commenced a tender offer, then “withdrew” it to purchase a dissident’s shares at a higher price, and then launched a “new” tender offer thevery next day at the original price.19  Instead of accepting defendants’ characterizations, the Field Court examined the surrounding circumstances to determine whether the formally separate offers should be considered a single, integrated transaction.  Because the defendants never “abandoned the goal of the original tender offer,” the Field Court concluded that they had not effectively terminated the initial tender offer, and that the “second” tender offer was merely a continuation of the first.20  Given this, the purchase of the dissident’s shares violated Rule 14d-10.  

The Gerber Court found that Computer Associates, like the defendants in Field, had “continuously pursued the goal of its tender offer.”21  Because the Berdy agreement was signed during the tender offer and payment was made “in support of [Computer Associates’] continuous goal” of acquiring On-Line, the Court concluded that the payment also occurred “during the tender offer” for purposes of Rule 14d-10, and held that Gerber’s claims were sufficient as a matter of law.22  


On appeal, the Second Circuit also considered whether the district court erred in instructing the jury that it could find Computer Associates paid $5 million to Berdy “partly for the shares and partly for the agreement not to compete.”23  Computer Associates argued that there was no evidentiary basis for this apportionment, and that the jury’s finding that $2.34 million was payment for Berdy’s shares represented an impermissible compromise verdict.  The Court of Appeals reviewed the jury instructions de novo and found sufficient evidence to support the jury’s finding, based on the testimony of Computer Associates’ own expert witnesses.  One witness testified, for example, that, if Berdy competed, the expected loss to Computer Associates could range from $0 to $5 million.  The Court of Appeals held: (a) this was sufficient evidence for a jury to find that some, but not all, of the $5 million was consideration for Berdy’s On-Line shares; and (b) the verdict was not an impermissible compromise because it was supported by the trial evidence.24

The Functional Approach: Other Decisions
Other courts adopting the functional approach include the Court of Appeals for the Ninth Circuit, and United States District Courts in Tennessee and Pennsylvania.  The Ninth Circuit adopted the functional approach in Epstein v. MCA, Inc., 50 F.3d 644 (9th Cir. 1995).25  The litigation grew out of Matsushita Electrical Company’s tender offer for MCA, and its entering into employment agreements with MCA executives Lew Wasserman and Sidney Sheinberg.


Rather than tendering his shares, Wasserman exchanged them for preferred stock in a wholly owned Matsushita subsidiary.  The agreement was signed moments before the tender offer commenced, and the preferred stock changed hands about one hour after the tender offer closed.  Sheinberg, on the other hand, tendered his shares, but MCA agreed to pay him an additional $21 million if the tender offer succeeded.  Two days after Matsushita accepted all tendered shares, MCA paid Sheinberg the promised $21 million.


The district court denied plaintiffs’ motion for summary judgment on their Rule 14d-10 claim and instead granted summary judgment to Matsushita.  Plaintiffs appealed, and Matsushita argued that Rule 14d-10 was inapplicable because both the payments and the agreements were made outside the formal tender offer period.  The Ninth Circuit rejected this argument, noting that the phrase “tender offer” has never been interpreted as denoting a rigid period of time, and that if the Court were to adopt such a rigid test, Rule 14d-10 would be drained of all force.26


Instead, the Court held that “[a]n inquiry more in keeping with the language and purposes of Rule 14d-10 focuses not on when Wasserman was paid, but on whether the Wasserman transaction was an integral part of [the]  tender offer.”27  The court found that the Wasserman transaction was integral because it was “in several material respects conditioned on the terms of the public tender offer”: the redemption value of Wasserman’s stock referred to the tender offer price, and the transaction hinged upon the tender offer’s success.28  

Finally, the court rejected Matsushita’s argument that the Sheinberg agreement could not violate Rule 14d-10 because the Rule applied only to the acquiror, whereas it was MCA, the target, that had paid Sheinberg.  The court reasoned that the mere fact that MCA issued the check just before merging with Matsushita did not preclude the possibility that the payment was meant to induce Sheinberg’s support of Matsushita’s tender offer.29  


More recently, district courts in Tennessee and Pennsylvania have also adopted the functional approach.  In Katt v. Titan Acquisitions, Ltd., 133 F. Supp. 2d 632 (M.D. Tenn. 2000), the court denied a motion to dismiss Rule 14d-10 claims based on $30 million in golden parachute payments, accelerated incentive awards, “sign on” bonuses, and accelerated performance awards to target executives.  These agreements were made and consummated outside the tender offer period; in fact, many of these agreements had been made months before, and the sign-on bonuses, for example, were not paid until months after the tender offer closed.


But, under the functional approach, the court held that the agreements could be an “integral part” of the tender offer because: they were “executed in close connection with [the] tender offer,” the “officers’ contractual rights [were] tied to the success of [the] tender offer,” the “officers [were] shareholders and these agreements [were] inextricably joined with [the] tender offer, the success of the acquisition and these officers’ support of the acquisition.”30  Although the payments were made by the target, the court concluded that the payments could be found to have been induced by the acquiror, and thus remained subject to Rule 14d-10.

In Millionerrors Investment Club v. General Electric Co., 2000 U.S. Dist. LEXIS 4778 (W.D. Pa. Feb. 8, 2000), a district court in Pennsylvania denied a motion to dismiss Rule 14d-10 claims based on stock options granted to executives of the target.  These in-the-money options were granted shortly before the tender offer commenced, and were cancelled, as soon as the tender offer closed, in exchange for cash payments pegged to the difference between the options’ strike price and the tender offer price.  Although actual payment was not made until several months after the tender offer closed, nevertheless the court denied the motion to dismiss because the acquiror’s “agreement to cancel and cash out the [target] executive[s] unvested stock options occurred ‘during’ the Tender Offer.”31  The court stated: “We agree with the less rigid interpretation of Rule 14d-10 utilized by the [court] in Epstein. . . .  That interpretation is more attuned to the SEC’s  . . . goal of ensuring ‘equality of treatment among all shareholders who tender their shares.’”32


The functional approach arguably sweeps too broadly, placing many post-merger employment agreements with target management at risk because they may be considered “integral to,” or executed “continuously in pursuit of,” the tender offer.  Furthermore, the factually nuanced nature of the functional approach makes it likely that a Rule 14d-10 claim will survive a motion to dismiss and perhaps summary judgment.  Given this and given most corporations’ unwillingness to hazard their futures on the dice roll of a jury verdict, the threat of huge liability engendered by the functional approach creates significant settlement leverage for plaintiffs.  

The Formal Approach

Under the “formal” or “bright-line” approach, additional consideration violates Rule 14d-10 only if it is literally paid during the tender offer.  Lerro v. Quaker Oats Co., 84 F.3d 239 (7th Cir. 1996) is the foremost bright-line case, and arose out of Quaker Oats’ acquisition of SnappleBeverage Corporation.  The case involved a lucrative distribution agreement with one of the target’s controlling shareholders, which plaintiff alleged was a disguised additional payment for shares.


The Seventh Circuit acknowledged that the agreement was integral to the transaction, and that its consummation depended on the merger.  Nevertheless, the Seventh Circuit upheld the district court’s dismissal of the complaint because the challenged agreement was signed three days before the tender offer period began.  “The difference between ‘during’ and ‘before’ (or ‘after’) is not just linguistic,” stated the court.  “It is essential to permit everyone to participate in the markets near the time of a tender offer.  Bidders are forbidden to buy or sell on the open market or via negotiated transactions during an offer . . . but they are free to transact until an offer begins, or immediately after it ends.”33

More recently, the United States District Court for the District of Delaware adopted the Lerro rationale in In re Digital Island Securities Litigation, 2002 U.S. Dist. LEXIS 17906 (D. Del. Sept. 10, 2002).  In that case, plaintiff shareholder alleged that the target’s directors and officers received extra compensation in the form of salary and stock options packages.  The court dismissed the claim because any “extra compensation” was negotiated and agreed to before the tender offer.34


Similarly, in Susquehanna Capital Group v. Rite Aid Corp., 2002 U.S. Dist. LEXIS 18290 (E.D. Pa. Sept. 17, 2002), a district court in Pennsylvania also dismissed plaintiff’s Rule 14d-10 claim where both the agreement and the payment were made before the tender offer began.  Plaintiff, a market-maker in convertible securities, entered into an agreement with defendant Rite Aid Corporation, to exchange Rite Aid Convertible Notes for Rite Aid common stock.  Less than two weeks later, Rite Aid launched a tender offer at a higher conversion ratio.  The court cited Lerro in finding that plaintiff’s agreement did not occur during the tender offer period, but also noted, without explanation, that Millionerrors, Epstein and Field were not inconsistent.35

Finally, in Walker v. Shield Acquisition Corp., 145 F. Supp. 2d 1360 (N.D. Ga. 2001), the court dismissed plaintiff’s Rule 14d-10 claims based on various “Retention and Transition Awards” paid to target executives following a tender offer and back-end merger.  These awards were promised before the tender offer began, but the merger agreement conditioned their payment upon the merger’s success.  Plaintiff argued that the awards were an “integral part” of the tender offer, but the court rejected plaintiff’s argument, holding that because the awards had been promised before the tender offer began, and the payments were made after the tender offer closed, the Rule 14d-10 claim failed.


Although the bright-line approach offers predictability, it may at times not reach far enough.  Under this approach, even improper payments could theoretically skirt Rule 14d-10, so long as no money changes hands between the beginning and end of the tender offer.

Conclusion

The SEC’s Division of Corporation Finance and the securities bar have been discussing the interplay between post-merger employment agreements with target management and tender offers, but whether the discussions will result in proposed rulemaking is unclear.  Absent clarification from the SEC, it remains to be seen whether, given the Circuit split, the Supreme Court will grant a writ of certiorari to resolve these issues.



1.        17 C.F.R. 240.14d-10.
2.        Amendments to Tender Offer Rules All-Holders and Best-Price, Securities Act Release No. 6653, 36 S.E.C. Docket 96 (July 11, 1986).
3.        17 C.F.R. 240.14d-10.
4.        See Section 14(d)(7).  Consider a target executive who tenders 10,000 shares for $50 each, and who receives a $1 million bonus during the tender offer.  If the bonus is found to be “increased consideration,” that would amount to a $100 per share premium – twice the tender offer price.  This means that a $5 billion tender offer could carry a $10 billion liability.

5.        Gerber v. Computer Assoc. Int’l, Inc., 812 F. Supp. 361, 363 (E.D.N.Y. 1993).
6.        Plaintiff also alleged a violation of Rule 10b-13, for which the court granted Computer Associates’ motion to dismiss.  Gerber, 812 F. Supp. at 368.
The SEC promulgated Rule 10b-13, which was later replaced by Rule 14e-5, to further protect tendering shareholders from price discrimination in tender offers. Generally, Rule 10b-13 prohibited side transactions involving purchases of shares subject to a tender offer.  See Field v. Trump, 850 F.2d 938, 943 (2d Cir. 1988).
7.        Id. at 364.
8.        Id. at 363.
9.        Gerber, 1995 U.S. Dist. LEXIS 21142 (E.D.N.Y. Apr. 7, 1995).
10.        Gerber, 2000 U.S. Dist. LEXIS 21726 (E.D.N.Y. March 14, 2000).
11.        In April, 1993, plaintiff filed an amended complaint alleging violations of Rule 14d-10 and Rule 10b-5. The court granted Computer Associates’ motion for summary judgment on the Rule 10b-5 claim. Gerber, 2000 U.S. Dist. LEXIS 21726 at *7.
12.        See Gerber, 303 F.3d 127 at 131 (citing to district court trial transcript at 825).

13.        Berdy owned about 25% of the company’s outstanding shares, which helped cushion much of the blow of the jury verdict.  Once the $2.34 million – what the jury found to be unlawful compensation – was divided among the number of shares that Berdy tendered, the figure came out to an extra $1.46 per share plus interest.  This amounted to a total judgment for the class of $5.67 million.  Gerber, 2000 U.S. Dist. LEXIS 21727 at *7 (E.D.N.Y. Nov. 7, 2000).
14.        Id. at *4, *5.
15.        Gerber, 303 F.3d at 135.
16.        Id.
17.        Id.
18.        Id.
19.        Field, 850 F.2d at 940-942.
20.        Id. at 945.
21.        Gerber, 303 F.3d at 136.
22.        Id.
23.        Id.
24.        Id. at 137-138.
25.        Rev’d on other grounds sub nom. Matsushita Elec. Indus. v. Epstein, 516 U.S. 367 (1996) (holding that federal court may not withhold full faith and credit from a state court judgment approving a class action settlement simply because the settlement releases claims within the exclusive jurisdiction of the federal courts).  
26.        Epstein, 50 F.3d at 654.
27.        Id. at 655.
28.        Id. at 656.

29.        Id. at 658-659.
30.        Katt, 133 F. Supp. 2d at 645.
31.        Millionerrors, 2000 U.S. Dist. LEXIS 4778 at *16.
32.        Millionerrors, 2000 U.S. Dist. LEXIS 4778 at *14-15.
33.        Lerro, 84 F.3d at 243.
34.        Digital Island, 2002 U.S. Dist. LEXIS 17906 at *36.
35.        Susquehanna Capital, 2002 U.S. Dist. LEXIS 18290 at *5.
   

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