"A federal court has found that merely posting a summary plan description (SPD) on a company intranet did not satisfy the electronic disclosure rules under ERISA.... The Court noted that 'the regulations relating to the disclosure of SPDs through electronic means require the SPD be 'furnished,' not simply made available.' [Thomas v. CIGNA Group Ins., No. 09-CV-5029 (E.D.N.Y. Mar. 2, 2015)]