59.  29 U.S.C. § 1132(a)(2) authorizes any participant or beneficiary of the Plan to  bring an action individually on behalf of the Plan to obtain for the Plan the remedies provided by  29 U.S.C. § 1109(a). Plaintiff seeks certification of this action as a class action pursuant to this  statutory provision and Fed. R. Civ. P. 23.   61.  Numerosity:  The Class is so numerous that joinder of all Class members is  impracticable. The Plan had approximately 9,000 to 10,000 participants at all relevant times  during the applicable period.   62.  Typicality:  Plaintiff’s claims are typical of the Class members’ claims. Like  other Class members, Plaintiff was a Plan participant and suffered financial harm as a result of  Defendant’s mismanagement of the Plan. Defendant treated Plaintiff consistently with other  Class members with regard to the Plan. Defendant’s imprudent and disloyal decisions affected all  Plan participants similarly.    63.  Adequacy:  Plaintiff will fairly and adequately protect the interests of the  Class. Plaintiff’s interests are aligned with the Class that they seek to represent, and Plaintiff has  retained counsel experienced in complex class action litigation, including ERISA litigation.  Plaintiff does not have any conflicts of interest with any Class members that would impair or  impede her ability to represent such Class members.   65.  Class certification is appropriate under Fed. R. Civ. P. 23(b)(1)(A) because  prosecuting separate actions against Defendant would create a risk of inconsistent or varying  adjudications with respect to individual Class members that would establish incompatible  standards of conduct for Defendant.    66.  Class certification is also appropriate under Fed. R. Civ. P. 23(b)(1)(B) because  adjudications with respect to individual Class members, as a practical matter, would be  dispositive of the interests of the other persons not parties to the individual adjudications or  would substantially impair or impede their ability to protect their interests. Any award of  prospective equitable relief by the Court would be dispositive of non-party participants’ interests.  The accounting and restoration of the property of the Plan that would be required under 29  U.S.C. §§ 1109 and 1132 would be similarly dispositive of the interests of other Plan  participants.   68.  As alleged above, Defendant is a  fiduciary with respect to the Plan and is subject  to ERISA’s fiduciary duties.   69.  29 U.S.C. § 1104 imposes fiduciary duties of prudence and loyalty upon the  Defendant in connection with its administration of the Plan and the selection and monitoring of  Plan investments.   70.  Defendant breached these fiduciary duties by engaging in the conduct described  herein.  Among other things, Defendant failed to employ a prudent and loyal process for  selecting, monitoring, and reviewing the Plan’s investment options, by improperly prioritizing  John Hancock’s proprietary investments over superior available options, and by failing to  critically or objectively evaluate the cost and performance of the Plan’s proprietary investments  in comparison to other investment options. In addition, Defendant caused the Plan to pay  excessive recordkeeping fees, and failed to properly monitor and control those expenses.    72.  Further, each of the actions and omissions described in paragraph 70 above and  elsewhere in this Complaint demonstrate that Defendant failed to discharge its duties with  respect to the Plan with the care, skill, prudence, and diligence under the circumstances then  prevailing that a prudent person acting in a like capacity and familiar with such matters would  have used in the conduct of an enterprise of like character and with like aims, in violation of 29  U.S.C. § 1104(a)(1)(B).   73.  As a consequence of Defendant’s fiduciary breaches, the Plan and its participants  suffered millions of dollars in losses.   74.  Defendant is liable, under 29 U.S.C. §§ 1109 and 1132, to make good to the Plan  all losses resulting from the aforementioned fiduciary breaches, to restore to the Plan any profits  Defendant made through the use of Plan assets, and to restore to the Plan any profits resulting  from its fiduciary breaches.  In addition, Defendant is liable for additional equitable relief and  other relief as provided by ERISA and applicable law.  Breach of Duties of Loyalty and Prudence  29 U.S.C. § 1104(a)(1)(A)–(B)  