SAN FRANCISCO - A Ninth Circuit U.S. Court of Appeals panel certified a question to the Delaware Supreme Court on Jan. 10, asking whether the fraud exception to the continuous ownership standard for maintaining a shareholder derivative lawsuit applies in a case where a merger was not merely designed to end the shareholders' derivative standing (Arkansas Teacher Retirement System, et al. v. Angelo R. Mozilo, et al., No. 10-56340, 9th Cir.; 2013 U.S. App. LEXIS 619).