With no explanation, chose the best option from "A", "B", "C" or "D". of the SPD are identical to the plan. Id. (citing Rhorer, 181 F.3d at 642). That is because SPDs must be “ ‘written in a manner calculated to be understood by the average plan participant, and ... sufficiently accurate and comprehensive to reasonably apprise such participants and beneficiaries of their rights and obligations under the plan.’ ” Id. (quoting 29 U.S.C.A. § 1022(a)). SPDs “provide communication with beneficiaries about the plan” but “do not themselves constitute the terms of the plan.” CIGNA Corp. v. Amara, — U.S. —, —, 131 S.Ct. 1866, 1878, 179 L.Ed.2d 843 (2011). We only reach the rule of contra proferentem and construe the terms of the SPD in Phillips’s favor, however, if a term remains ambiguous after applying ordinary contract principles. See High, 459 F.3d at 578-79 (<HOLDING>); Wegner v. Standard Ins. Co., 129 F.3d 814,

A: holding rule of contra proferentem only applied when term is ambiguous
B: recognizing rule
C: holding that exclusionary rule to be applied as a matter of state law is no broader than the federal rule
D: holding that factor 10 should not be applied when the victim is the only one at risk
A.