Loss of Benefit of Tax Deferral

[jpod]

We know what the IRS' correction methodologies are for failures to implement salary deferral elections. However, has anyone seen any literature on how one would measure someone's damages because the employer did not implement a salary deferral election (i.e., the loss of tax-deferred investing over a period of years)? If so, please share. Let's ignore for the sake of argument whether there is a cause of action against the employer or the fact which I recognize that any measure of damages has to be based on speculative assumptions, but I am trying to find out if any courts have laid out some standards.