With no explanation, chose the best option from "A", "B", "C" or "D". beneficiaries, fiduciaries, or the Secretary of Labor. 29 U.S.C. § 1132(a)(1) — (6). Section 502(e) of ERISA provides that "the district courts of the United States shall have exclusive jurisdiction of civil actions under this subchapter brought by the Secretary or by a participant, beneficiary, or fiduciary.” Id. § 1132(e)(1) (émphasis added). 4 . The only circuit to hold otherwise is the Ninth Circuit, which held in Fentron that an employer could sue even though not a party enumerated in the statute. Fentron, 674 F,2d at 1305 (analyzing the issue in terms of standing). See also, Award Serv., Inc. v. Northern Calif. Retail Clerks Unions & Food Employers Joint Pension Trust Fund, 763 F.2d 1066, 1068 (9th Cir.1985), cert. denied 474 U.S. 1081, 106 S.Ct. 850, 88 L.Ed.2d 890 (1986) (<HOLDING>). Other circuits have criticized the Ninth

A: holding that despite the specific provisions of section 502 an employer may bring an action under erisa to enforce its terms where the employer alleges specific and personal injury
B: holding an employer may partially enforce a noncompete agreement to the extent it is reasonable under the circumstances
C: holding that collective bargaining agent representing employees had representational standing and therefore could bring an action under section 502 of erisa
D: holding that supervisory employee is not an employer under the terms of cfepa and because the employer is liable for the employees actions a plaintiff may not maintain an action against the employee individually under conngenstat  46a60
A.