( September 29, 2025, 11:20 AM EDT) -- SAN FRANCISCO — Cross-appeals of an Employee Retirement Income Security Act documents case that resulted in statutory penalties of $765 were resolved against a health plan beneficiary, with the Ninth Circuit U.S. Court of Appeals saying in an unpublished memorandum disposition that Netflix Inc. “disclosed all required documents as soon as administratively practicable ahead of the March 1, 2021, disaster order deadline and did not act in bad faith, especially in light of the COVID-19 pandemic.”...