International Paper - PLANSPONSOR.com

Case 3:06-cv-00703-DRH-CJP Document 2 Filed 09/11/2006 Page 38 of 52A. Proudly extols that various investment options “outperformed theirrespective market benchmarks” (emphasis added), but fails to mention that theDefendants custom-designed such benchmarks (they are not recognized “market”benchmarks at all) and/or changed benchmarks without explanation, see e.g., the2004 Annual Review;B. States that the Plans’ “three drivers” are “Great Funds, Great Service andGreat Fees” (emphasis in original) and pledges to make “an already greatsavings program even better,” see e.g., the 2004 Annual Review; andC. Commends the Defendants’ efforts in creating the expensive multilayeredmaster trust structure discussed above, see e.g., the 2005 Annual Review(Emphasis original):After many years of transformation, I’m proud to say that IP has indeedcreated the Savings Plan of Choice -- an intelligently designed plan withGreat Funds, Great Service and Great Fees. And we intend to keep it thatway. We’ll continue to look for new ways to enhance the Plan, to meetyour needs and make it much more than meets the eye.Investment Management and Other Fees Assessed AgainstEmployer Stock Funds157. Employer stock funds or company stock funds (“Employer Stock Funds”) are aninvestment option in many 401(k) plans, especially those of large employers, like IPC, withstock that is publicly traded.158. As the name suggests, an Employer Stock Fund provides 401(k) plan participantswith the opportunity to use a portion of their 401(k) retirement savings to purchase stock in thecompany for which they work.38