"[T]he court held that a written request for pension benefit statements under ERISA Section 105 can be made electronically. Before this, no circuit court had addressed whether a request for a pension benefit statement through an online platform would constitute a 'written' request under ERISA, and a number of district courts had concluded that an online request was not sufficient. " [Bafford v. Northrop Grumman Corp., No. 20-55222 (9th Cir. Apr. 15, 2021)]