In a significant decision, the Delaware Chancery Court on December 19, 2018 held that certificates of incorporation in Delaware-chartered companies cannot have forum selection provisions requiring shareholder actions under the Securities Act of 1933 to be filed in federal court. In Sciabacucchi v. Salzberg, C.A. 2017-0931-JTL, slip op. (Del. Ch. Dec. 19, 2018), Vice Chancellor J. Travis Laster drew an important distinction between internal-affairs claims, such as derivative actions, which may be regulated by forum selection provisions, and external-affairs claims, such as actions under the 1933 Act, in which the plaintiff happens to be a stockholder but which concern the corporation’s external relationships.