Iroquois Brands, Ltd., is a food company that imports French foie gras, a pt made from the

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Iroquois Brands, Ltd., is a food company that imports French foie gras, a pâté made from the enlarged livers of force-fed geese. The French method for raising the geese is to funnel corn down the geese’s throats and gag them with rubber bands to keep them from regurgitating. A shareholder wishes to include in the proxy materials a proposal that the company study this method of force-feeding as an unethical business practice (cruelty to animals). Should the proposal be included? Does Section require that it be included? [Lovenheim v. Iroquois Brands, Ltd., 618 F. Supp. 554 (D.C. 1985)]

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