to ‘enforce their rights under the terms of the plan.’ ” (alteration omitted) (quoting 29 U.S.C. § 1132(a)(1)(B))). Accordingly, “in ERISA cases, state law does not control. Instead, general common law principles apply.” Devlin, 274 F.3d at 84 n.5; see also Merrick v. UnitedHealth Grp. Inc., 175 F.Supp.3d 110, 117 (S.D.N.Y. 2016) (“The validity of assignments for ERISA purposes is a question of federal common law.” (alterations and internal quotation marks omitted)). Courts outside of the Second Circuit have held that “[w]hen applying federal common law to contract issues, courts generally look to the Restatement for guidance.” United States ex rel. Ubl v. IIF Data Solutions, 650 F.3d 445, 451 (4th Cir. 2011); see also Bowden v. United States, 106 F.3d 433, 439 (D.C. Cir. 1997) (<HOLDING>). Defendants’ argument with respect to
holding that the restatement second of contracts is the source from which the court would be inclined to fashion a federal common law rule since those principles represent the prevailing view among the states holding that the rights and duties of the united states on commercial paper which it issues are governed by federal law and that in the absence of an applicable act of congress it is for the federal courts to fashion the governing rule of law according to their own standards holding that we view the evidence in the light most favorable to the prevailing party recognizing that the advisory committee note expressly states that the rule is substantially a restatement of existing law  holding that federal common law is the law that would govern in the absence of the warsaw convention