CHAPMAN v. SUPP. BEN. RETIREMENT PLAN OF LIN TELE. Cite as 723 F.Supp.2d 485 (D.R.I. 2010) and direct a campaign of murder against civilians amply justifies the imposition of punitive damages against it and the CGIB. North Korea’s budget for the export of terrorism is not known. However, this Court will adopt the ‘‘typical punitive damages award of $300 million’’ that has been awarded against the Islamic Republic of Iran because ‘‘[t]here is no reason to depart from settled case law regarding the amount of punitive damages in terrorism cases.’’ Brewer v. Islamic Republic of Iran, 664 F.Supp.2d 43, 58–59 (D.D.C. 2009), see also Acosta v. Islamic Republic of Iran, 574 F.Supp.2d 15, 31 (D.D.C.2008). Accordingly, the Court will award punitive damages against defendants in the amount of $300 million to plaintiffs collectively to be divided equally. CONCLUSION This Court possesses subject matter jurisdiction over this action and personal jurisdiction over defendants. Plaintiffs have established to this Court’s satisfaction, pursuant to 28 U.S.C. § 1608(e), and by clear and convincing evidence, that defendants are jointly and severally liable for all the damages awarded by this Court because of their provision of material support and assistance to the terrorists who carried out the Lod Airport Attack on May 30, 1972 in which plaintiffs were injured. Accordingly, plaintiffs’ motion for default judgment shall be granted against defendants and judgment shall be entered against defendants and in plaintiffs’ favor in accordance with this opinion and order. IT IS SO ORDERED. , 485 Gary CHAPMAN, Plaintiff, v. SUPPLEMENTAL BENEFIT RETIREMENT PLAN OF LIN TELEVISION CORPORATION and Subsidiary Companies and LIN Television Corporation, individually and as Administrator and Fiduciary, Defendants. C.A. No. 09–518 S. United States District Court, D. Rhode Island. July 16, 2010. Background: Television corporation employee, a high-level executive who, acting upon advice of counsel, had entered into ‘‘Employment Transition Agreement and General Release’’ with employer outlining severance package that included large lump-sum payment brought Employee Retirement Income Security Act (ERISA) action against supplemental benefit retirement plan and employer, individually and as administrator and fiduciary, over dispute concerning calculation of his pension benefits due pursuant to plan. Defendants moved for summary judgment on basis that ERISA claims were barred by release, and employer moved for partial summary judgment on its counterclaim, arguing that employee violated promise not to sue contained in agreement. Holdings: The District Court, William E. Smith, J., held that: (1) employer did not waive its defense with respect to release, and (2) plain language of agreement included preservation of claims at issue. Motions denied. 1. Labor and Employment O555 Federal common law requires heightened scrutiny for waivers of ERISA pen-

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