Consider what must occur to create such creatures. First, an individual must fail to win a majority of shareholder votes, a rare event at most public companies. Among the more than 2,300 companies and 21,640 directors we reviewed, the average level of shareholder support last year was 95.3%. Second, the director must be nominated for election or reelection to a board where plurality voting is the rule, or where, under certain majority-rule standards, their fellow directors are able to reject their duly submitted resignations. Only if the director survives these challenges do they arise undead. And by then, it may be too late.