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Case 3:06-cv-00703-DRH-CJP Document 2 Filed 09/11/2006 Page 11 of 52xiii. Are responsible to account for the assets and transactions of thePlans and should be surcharged for any transactions and paymentsfor which they cannot account.C. Typicality. The claims brought by the Plaintiffs are typical of those of theabsent Class members, in that:i. The Defendants owed the exact same fiduciary and other ERISAbasedobligations to each of the Plans’ participants andbeneficiaries, and each member of the Class;ii.The Defendants’ breach of those obligations constitutes a breach toeach of the Plans’ participant and beneficiary, and each member ofthe Class;iii. To the extent that there are any differences in Class members’damages, such differences would be a product of simplemathematics based upon account balances in the Plans. Suchminimal and formulaic differences are no impediment to classcertification.D. Adequacy of Representation. The Plaintiffs are adequate representativesof the absent Class members and will protect such absent Class members’interests in this litigation. The Plaintiffs do not have any interests antagonistic tothe other class members nor do they have any unique claims or defenses thatmight undermine the efficient resolution of the Class’ claims. Plaintiffs haveretained competent counsel, versed in ERISA, class actions, and complexlitigation.11