Paciello v. Unum Life Insur. Co., 2000 U.S. App. LEXIS 11580 (2^nd Cir. May 23, 2000) (unpublished)-This court affirmed the district court's denial of Paciello's petition for class certification on her claim that UNUM Life Insurance Company failed to satisfy ERISA's requirement that claim denial letters state the following:  "(a) the specific reason for the denial; (b) a specific reference to pertinent plan provisions on which the denial is based; (c) a description of any additional information necessary for a claimant to perfect her claim and an explanation of why such material is necessary; and (d) appropriate information as to the steps to be taken if the participant or beneficiary wishes to submit his or her claim for administrative review."

            In this case, class certification failed because of the "typicality and commonality" requirements.  (See Fed. R. Civ. P. 23(a)).  Because denial letters varied not only between Unum's regional offices, but also as to each individual patient, this court agreed that a class action would not be an economical vehicle of adjudication.