"The Third Circuit agreed that the catalyst theory applied, but ... held that all that was necessary was that litigation activity pressed Defendants to settle or give Plaintiffs the requested relief. It explained that the victory must be voluntary, non-trivial, and more than a procedural victory that is apparent to the court without the need to conduct a lengthy inquiry into whether that success was substantial or occurred on a central issue." [Templin v. Independence Blue Cross, No. 13-4493 (3d Cir. May 8, 2015)]