The duty of a board to monitor and oversee organizational risk includes cyberrisks. As cyberrisks and incidents proliferate, boards are seeking to enhance the information they receive about cyberrisks and incidents. One development boards should be aware of is the decision in the Palkon v. Holmes directors and officers (D&O) litigation (2014 U.S. Dist. LEXIS 148799 (D.N.J. Oct. 20, 2014)).