With no explanation, chose the best option from "A", "B", "C" or "D". Congress has authorized the courts “to formulate a nationally uniform federal common law to supplement the explicit provisions and general policies set out in [the Act].” Peterson v. American Life & Health Ins. Co., 48 F.3d 404, 411 (9th Cir.1995). In that regard, we have held that “ERISA preemption does not mean that general principles of state law are irrelevant to interpretation of ERISA-governed insurance contracts.” Saltarelli v. Bob Baker Group Medical Trust, 35 F.3d 382, 386 (9th Cir.1994). On the contrary, courts are directed to formulate federal common law by considering both state law and governing fed 330, 1335 (11th Cir.1995) (assuming right of rescission exists under ERISA-created federal common law); Nash v. Trustees of Boston Univ., 946 F.2d 960, 966-67 (1st Cir.1991) (<HOLDING>); Coots v. United Employers Fed’n, 865 F.Supp.

A: holding that under federal law the party seeking to obviate the forum selection clause must prove that the inclusion of the clause was the result of fraud or coercion  fraud in the inducement as to the entire contract is not enough
B: holding that federal common law governs equitable remedies available under erisa
C: holding that federal common law of erisa preempts state law in the interpretation of erisa benefit plans
D: recognizing fraud in the inducement as defense under federal common law interpreting erisa
D.