A man who opposed the Vietname War was a shareholder of Honeywell and decided to file a section 220 suit in order to get all the documents about arms manufacturing by Honeywell. He claimed his purpose was to communicate with other shareholders and to convince Honeywell to stop making weapons.
The court says that it is not proper to if you want the shareholder list just to communicate to other shareholders. The purpose for such a communication has to be proper.
In Credit Bureau, the court said that an ancillary purpose to getting a shareholder list is irrelevant, as long as there is at least one relevant purpose to getting the list.