"This decision reinforces the Ninth Circuit's narrow interpretation of Section 104, limiting disclosures to documents directly relevant to participants' understanding of their benefits and procedures. It also highlights the role of COVID-19 disaster relief orders in excusing compliance delays, where plan administrators act in good faith and provide documents as soon as practicable." [Zavislak v. Netflix, Inc., No. 24-4156 (9th Cir. Sep. 24, 2025; unpub.)]  MORE >>