Excerpt: Two recent district court decisions highlight the fact that administrators issuing unclear or incomplete claim denial letters do so at their own peril. In both Tinker v. Versata, Inc. Group Disability Income Insurance Plan, No. 2:06-CV-02906 (E.D. Cal. July 13, 2008) and O'Connell v. Northland Lutheran Retirement Community Employee Benefit Plan, No. 07-C-637 (E.D. Wis. July 15, 2008), judges imposed significant penalties on plans for failing to live up to ERISA's standards in their explanations of claim denials.