"In a decision that overlooked key COBRA guidance, a federal district court ruled that an employer/plan administrator fulfilled its notice obligation by verbally providing a notice of COBRA rights and accepting premium payments -- which apparently the qualified beneficiary had to pay a few days after her employment termination.... [The court's] reasoning did not consider federal regulations that describe the form and structure of COBRA notices. It also did not consider that an employer is required to give a qualified beneficiary at least a 60-day election period and at least 45 days from the election date to pay the initial COBRA premium." [Madonia v. S 37 Management, Inc., No. 14-C-678 (N.D. Ill. Aug. 14, 2014)]