The U.S. Third Circuit Court of Appeal found that: “Rejecting a proportionality rule with regard to Section 1132(g)(2)(D) is consistent with the purpose of the provision. ERISA provides for ‘appropriate remedies, sanctions, and ready access to the Federal courts’ in order to ‘protect interests of participants in employee benefit plans and their beneficiaries.’ When delinquencies are small, the cost of recovery may be disproportionate, and requiring proportionality would, in effect, discourage plans from taking their claims to federal courts.” See United Auto Workers v. Metro Auto Center, No.05-4974, 2007 WL 2472237 (3d Cir. Sept. 4, 2007).