5.  Plaintiffs are each insured by a health insurance plan that is sponsored by their  employer and governed by the Employee Retirement Income Security Act of 1974 (“ERISA”)  (the “Plans”).     6.  The Plans are fully insured.     7.  Blue Shield is responsible both for paying claims under the Plans and for  administering the Plans.     8.  Plaintiffs’ Plans cover in- and out-of-network treatments for illnesses and  injuries as well as for mental illnesses and substance use disorders described in the Diagnostic  and Statistical Manual, Fifth Edition (“DSM-5”) of the American Psychiatric Association.  As  such, Plaintiffs’ Plans cover residential and intensive outpatient treatment for mental illnesses  and substance abuse disorders.     INJUNCTIVE RELIEF UNDER 29 U.S.C. § 1132(a)(3)(A)  188.  Plaintiffs incorporate by reference the preceding paragraphs as though fully set  forth herein.  189.  Plaintiffs bring this cause of action individually and on behalf of the Class.  190.  Plaintiffs and the Class have been harmed, and are likely to be harmed in the  future, by Defendants’ breaches of fiduciary duty described hereinabove.  191.  To remedy these injuries, Plaintiffs and the Class are entitled to seek, and do  seek, an injunction prohibiting these acts and practices pursuant to 29 U.S.C. § 1132(a)(3)(A),  and seek a judgment in their favor ordering Defendants to reprocess claims for residential  rehabilitation treatment and intensive outpatient treatment for substance abuse and mental  health disorders that they previously denied in whole or in part, pursuant to new guidelines that  are consistent with generally accepted professional standards and the Class members’ plans. 