self There are almost 600,000 U.S. 401(k) plans. These plans collectively cover more than 100 million participants. They have nearly $6 trillion in assets. Two principal laws governing these plans, the Internal Revenue Code (the "Code") and the Employee Retirement Income Security Act (ERISA), set out a series of rules that are mind-numbingly complex. In or about 2007, a plaintiff class action law firm sued a dozen very large 401(k) plans of name-brand employers generally alleging plan mismanagement. What started as a "trickle" of lawsuits morphed into a torrent in the years that followed, and there is no sign of the trend abating. Plan sponsors have responded by focusing