elaim[ ] involves the recovery and distribution of Plan assets on behalf of the Plan rather than determination of personal causes of action brought by individuals, ... separate actions by individual plaintiffs would impair the ability of other participants to protect their interests if the suit proceeded outside of a class context.” Id. Therefore, Mr. Tatum’s claim meets the requirements of Rule 23(b)(1)(B). Indeed, numerous courts have held that “‘ERISA litigation [involving a claim for breach of fiduciary duty] presents a paradigmatic example of a(b)(l) class’ ”. In re Global Crossing Ltd. Sec. & ERISA Litig., 225 F.R.D. 436, 453 (S.D.N.Y.2004) (quoting Kolar v. Rite Aid Corp., 2003 U.S. Dist. LEXIS 3646, 2003 WL 1257272 (E.D.Pa. March 11, 2003)); In re Williams, 231 F.R.D. at 425 (<HOLDING>); In re Ikon, 191 F.R.D. at 466 (“given the
holding that a a representative plaintiff acts as fiduciary for the others requiring the representative to act in the best interest of class holding that tolling applies to a subsequent class action when the prior denial of class certification was based solely on rule 23 deficiencies of the putative representative holding that due to erisas distinctive representative capacity and remedial provisions class treatment under rule 23b1b is appropriate holding that a district of columbia consumer protection statute that authorized representative actions and did not reference class action requirements or mandate class certification was a separate and distinct procedural vehicle from a class action and thus did not constitute a class action under cafa holding that the claims of the class representative and class members must be based on the same legal or remedial theory