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It seems that everyone has a smartphone or a tablet, and I cant think of anyone I know who does not have Internet access at home. Consequently, plan sponsors ask all the time if they can just email plan documents to employees to satisfy the notice requirements, or maybe just post new plan documents on the company intranet.
Well, the recent decision in Thomas v. CIGNA (E.D.N.Y.) serves as a reminder that the short answer to that question is no.
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