13.  Definition of Class.  The class consists of all individuals who:  (1)  have been, are or will be participants or beneficiaries  under the Plan, at any time on or after October 3, 2009  and/or the relevant statute of limitations; and  (2)  have required, require or are expected to require  treatment  in  an  outdoor/wilderness  behavioral  healthcare program or programs for a mental health  condition.   14.  Size of Class.  The class of Plan participants and beneficiaries who have  required treatment in outdoor/wilderness behavioral healthcare programs for a mental  health condition is expected to be so numerous that joinder of all members is  impracticable.   21.  During the relevant time periods, N.F., A.H. and class members have been,  are or will be participants or beneficiaries of the Microsoft Corporation Welfare Plan  which is subject to the Employee Retirement Income Security Act of 1974, pursuant to  26.  Plaintiffs re-allege all paragraphs above.   27.  Microsoft is a fiduciary under ERISA § 3(21)(A), 29 U.S.C. § 1002(21)(A),  because it is identified in the Plan as the Plan Administrator and named fiduciary.     28.  ERISA imposes strict fiduciary duties upon plan fiduciaries.  ERISA  § 404(a)(1)(C), 29 U.S.C. § 1104(a)(1)(C), states, in relevant part, that a plan fiduciary  must discharge its duties with respect to a plan “solely in the interest of the participants  and beneficiaries and … in accordance with the documents and instruments governing  the plan insofar as such documents and instruments are consistent with the provisions  of this title and Title IV.”   34.  Plaintiffs re-allege all paragraphs above.   35.  ERISA § 502(a)(1)(B), 29 U.S.C. § 1132(a)(1)(B) provides that a participant  or beneficiary may bring an action to “recover benefits due to him under the terms of his  plan, to enforce his rights under the terms of the plan, or to clarify his rights to future  benefits under the terms of the plan.”   36.  Plaintiffs and the class they seek to represent are entitled to recover  benefits due them due to the improper exclusion and/or limitation of coverage of  medically necessary mental health treatment in wilderness therapy programs.  They are  also entitled to a declaration of their rights to coverage of medically necessary mental  health treatment in outdoor/wilderness behavioral healthcare programs without the  application of Microsoft’s blanket exclusions and limitations.  37.  Plaintiffs re-allege all paragraphs above.   38.  Pursuant to ERISA § 502(a)(3), 29 U.S.C. § 1132(a)(3), plaintiffs and the  class seek to have Microsoft provide the class with corrective notice and information,  including reformation of the relevant health plan documents.   BREACH OF FIDUCIARY DUTIES  ERISA §§ 404(a)(1), 502(a)(2); 29 U.S.C. §§ 1104(a), 1132(a)(2)   CLAIM TO OBTAIN OTHER EQUITABLE RELIEF AND TO ENFORCE THE  TERMS OF THE PLANS  ERISA § 502(a)(3), 29 U.S.C. § 1132(a)(3)   CLAIM FOR RECOVERY OF BENEFITS, CLARIFICATION OF RIGHTS  UNDER TERMS OF THE PLANS   ERISA § 502(a)(1)(B), 29 U.S.C. § 1132(a)(1)(B)  