The Harvard Law Corporate Governance Blog Blog summarizes a Delaware Chancery case that might apply to lawsuits nationwide involving businesses incorporated in Delaware.  Note that the decision is based upon the Corporate Code, applicable to Delaware corporations, and not jurisdictional discovery rules –

Chancery Orders Production of Records for Periods Prior to Stock Ownership, by Francis G.X. Pileggi, Fox Rothschild LLP.

The Delaware Court of Chancery issued a decision last week of both practical and theoretical importance for corporate lawyers. The opinion is Melzer v. CNET Networks, Inc…..

 the court held that Section 220 of the Delaware General Corporation Law, which is the statutory basis on which stockholders can demand books and records of a company, enables plaintiffs under certain circumstances to receive documents for a period prior to their stock ownership…

Francis has a more thorough analysis of the case on his Delaware Litigation Blog.