The Third Circuit held that the catalyst theory of recovery applies to ERISA cases when determining whether to award attorneys’ fees.  In this case, Plaintiffs (two individuals and two pharmacies) filed suit against Defendant insurance companies for denial of benefits under ERISA.  After their motion to dismiss was denied, Defendants paid the claims in full.  Both parties then sought attorneys’ fees and costs, which the district court denied.  The Third Circuit affirmed the district court’s decision to deny fees, but remanded on the issue of whether Plaintiffs were entitled to interest on the delayed payment of benefits.  Ultimately, the Defendants agreed to pay $68,000 in interest to Plaintiffs and the case settled.