Stroh v. Blackhawk Holding Corp.

Blackhawk Holding Corp. (defendant) issued Class A and Class B stock; Class B shares carried a vote in corporate matters but, under the articles of incorporation, were entitled to no dividends of any kind. Stroh and other Class B holders (plaintiffs) sued, arguing this dividend exclusion effectively invalidated their stock, pointing to Illinois's statutory definition of "shares" as units of "proprietary" interest in a corporation, which they argued necessarily implied some economic interest.