International Paper - PLANSPONSOR.com

Case 3:06-cv-00703-DRH-CJP Document 2 Filed 09/11/2006 Page 9 of 52B. Commonality. Common issues of fact and law predominate over anyissues unique to individual Class members. Issues that are common to all ClassMembers include, but are not limited to, whether the Defendants:i. Charged fees and expenses to the Plans that were, or are,unreasonable and/or not incurred solely for the benefit of thePlans’ participants;ii.Caused the Plans to enter into agreements with third-parties whichcaused and/or allowed the Plans to pay fees and expenses that were,or are, unreasonable and/or not incurred solely for the benefit ofthe Plans’ participants;iii. Failed to monitor the fees and expenses paid by the Plans and, bysuch failure, caused or allowed the Plans to pay fees and expensesthat were, or are, unreasonable and/or not incurred solely for thebenefit of the Plans’ participants;iv.Failed to inform themselves of, and understand, the variousmethods by which vendors in the 401(k), financial and retirementindustry collect payments and other revenues from 401(k) plans;v. Failed to establish, implement, and follow procedures to properlyand prudently determine whether the fees and expenses paid by thePlans were reasonable and incurred solely for the benefit of thePlans’ participants;9