Apple / Icahn: Smaller slice Best traits of activist investors? Limited shame and lots of creativity. Carl Icahn had wacky recapitalisation schemes at Dell and promised "years of litigation" if his views were dismissed. He then meekly submitted to Michael Dell's buyout. At Apple, Mr Icahn's $150bn buyback scheme has stalled and he is walking it back to a humble $50bn. For all the tweets, cable-TV histrionics and spreadsheets, these are middling results relative to all the bluster and fancy maths. Yet at Dell, Mr Icahn achieved a higher buyout price by getting Mr Dell to bid against himself. At Apple, Mr Icahn has shown the company's $100bn capital return plan to be inadequate. Ordinary investors get a good show - and modestly improved results in situations that seemed hopeless. Mr Icahn, following in David Einhorn's footsteps, asserted that borrowing $150bn and using it to buy back shares would increase Apple's share price by a third. Set aside the difficulty of raising that amount of debt and the wisdom of carrying it. Apple's plan of $100bn in capital return by 2015 is timid. It holds $147bn in cash and its free cash flow through 2015 is estimated at about $100bn. So another $50bn in share repurchases is reasonable. Should Apple assent, Mr Icahn deserves credit for being a catalyst. Between activist agitation, operating results and a market rally, Apple's shares have reached a 52-week high. The question is this: had Mr Icahn simply asked for a 23 cent bump in the Dell offer, or only requested a $50bn buyback at Apple, would he have been successful? Maybe not. The oddball recapitalisation and debt-funded buyback were so outrageous that they inspired deep scrutiny of the machinations of Dell and Apple. Mr Icahn's pronouncements are often laughable. Incremental victories for shareholders are not.