 Options to increase a portfolio's performance by generating Legal Alpha include for example (a) active, coordinated proxy voting and shareholder activism to produce sustainable, long-term value of the target company, (b) the systematic pursuit and recovery of losses by participating in class-action settlement disbursements, (c) actively pursuing compensation claims in private or class actions, or (d) the selective pursuit of appraisal actions.While Legal Alpha is never an absolute performance increase indicator, it is always a relative performance enhancer in situations where a portfolio was affected by external, uncontrollable circumstances such as fraud.However, a portfolio must not have suffered a negative performance in order to warrant the efforts to generate Legal Alpha.