16.  Definition of Class.  J.R. proposes the following class:  All individuals who:  (a) have been, are, or will be participants or beneficiaries under  Catholic Health Initiatives Medical Plan in effect or renewed  on or after August 10, 2012 and/or the relevant limitations  period; and  (b) have received, require, or are expected to require ABA  therapy for the treatment of ASD.   17.  Size of Class.  The class of persons who have received, require or  are expected to require ABA for the treatment of ASD, and who have been, are or will be  beneficiaries under the Plan, is expected to number in the hundreds and is so large that  joinder of all members is impracticable.   25.  During certain time periods on and after August 10, 2012, J.R. and  members of the class have been, are or will be participants or beneficiaries of the Plan,  which is subject to ERISA pursuant to 29 U.S.C. § 1003.    26.  During the class period, and continuing to the present, J.R. and  other members of the class have been diagnosed with ASD.    27.  During the class period and continuing to the present, Plaintiff J.R.  and other members of the class have required, currently require or will require ABA  services to treat their ASD.  As defined by the Plan, BCBSIL’s medical policy and relevant  state and federal law, their ABA services are “mental health services” which may be  medically necessary.     28.  As a standard practice and policy, Defendants have excluded all  coverage of such treatment through the application of exclusions and limitations.   29.  Specifically, Plaintiff J.R. was diagnosed with ASD by Kelly A.  Johnson, Ph.D. of the University of Washington’s Autism Center on or about  December 2, 2016.   45.  J.R. re-alleges all paragraphs above.   46.  Defendant CHI is a plan fiduciary under ERISA § 3(21)(A), 29 U.S.C.  § 1002(21)(A), because it is the Plan Administrator and Plan Sponsor.  Defendant CHI  exercises discretionary authority or discretionary control with respect to the denial and  appeal of denied claims under the Plan.   47.  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.”   48.  The terms of an ERISA plan include provisions of substantive  federal law, such as the requirements in the Federal Parity Act.  Defendants have failed  to comply with the terms of the Plan as modified by the requirements of the Federal  Mental Health Parity Act, and its implementing regulations.     49.  Defendants violated their obligations under ERISA § 404(a)(1),  29 U.S.C. § 1104(a)(1), by failing to act in accordance with the documents and  instruments governing the Plan and breached their fiduciary duties to J.R. and all class  members.   51.  J.R. re-alleges all the paragraphs above.   52.  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.”   53.  J.R. and the class are entitled to recover benefits due them under the  terms of the Plan.  They are also entitled to a declaration of present and future rights to  coverage of ABA services to treat ASD, a mental health condition.    54.  J.R. re-alleges all the paragraphs above.   BREACH OF FIDUCIARY DUTIES  ERISA §§ 404(a)(1), 502(a)(2); 29 U.S.C. §§ 1104(a), 1132 (a)(2)   CLAIM TO ENJOIN ACTS AND PRACTICES IN VIOLATION OF THE TERMS  OF THE PLANS, 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 AND CLARIFICATION OF  RIGHT TO FUTURE BENEFITS UNDER THE PLAN  ERISA § 502(a)(1)(B), 29 U.S.C. § 1132(a)(1)(B)  