769 F.Supp.2d at. 231. Likewise, ERISA elsewhere contemplates that governmental plans’can constitute a type of employee benefit plan in two different sections: ■ (1) 29 U.S.C. § 1002(32), which defines “governmental plan” vis-á-vis the government’s “employees,” who in turn require “employers’-’ under the statute, see id. § 1002(6); and (2) 29 U.S.C. § 1003(b)(1), which expressly provides for exclusion from liability for “governmental plans.” Accordingly, as in Tatum and Ve-era, the term “person’’ must be interpreted broadly enough to give the rest of the statute meaning. Third, the State’s rebanee on a single case interpreting the term “person” from the Securities Exchange Act of 1934 sheds little light on- the matter. See Brown v. City of Covington, 805 F.2d 1266, 1269 (6th Cir.1986) (<HOLDING>). To- state the obvious, what Congress meant
holding thatcities are not persons within the meaning of  3a9 of pre1975 version of securities exchange act of 1934 which defined person to mean an individual corporation a partnership an association a jointstock company a business trust or an unincorporated organization holding of wilko equally applicable to cases arising under the securities exchange act of 1934 holding that claims under the securities act of 1934 and the rico statutes are arbitrable holding that a state was embraced within the meaning of the word person  where the word person was defined as meaning and including a partnership association company or corporation as well as a natural person holding that each individual member of an unincorporated association is a client of the associations lawyer