In Gordon v. Verizon Communications (Feb. 2, 2017), the New York Appellate Division showed greater receptivity toward non-monetary settlements (possibly including “disclosure-only” settlements) than the Delaware courts have since the Court of Chancery's seminal 2016 Trulia decision. Based on Gordon, the plaintiffs' bar may seek to file M&A lawsuits in New York, when possible, rather than in Delaware. Delaware corporations that do not yet have a Delaware-only forum selection bylaw may now consider adopting one to ensure that the strict standards of Trulia will apply (thereby discouraging the plaintiffs' bar from bringing non-meritorious M&A suits). We note that a Delaware corporation headquartered in New York that has such a bylaw may decide to waive it and permit suit to be brought in New York if the company believes that would be a more favorable forum for the litigation or a potential settlement. In the attached Fried Frank M&A Briefing, we discuss other potential effects of the decision and offer related practice points.