"The complaint had alleged the company violated ERISA by offering GE stock as an investment option for its 401(k) plan participants despite purportedly under-reserving for the liabilities of insurance subsidiaries by approximately $15 billion. The court rejected the plaintiff's argument that her allegations satisfied the standard for pleading a breach of the duty of prudence in this context[.]" [Varga v. General Electric Co., No. 20-1144 (2d Cir. Feb. 4, 2021; unpub.)]