In this task, you will be shown a prompt from a judicial decision and multiple holding statements derived from citations following text in a legal decision.  Holdings represent the governing legal rule when the law is applied to a particular set of facts. There are five answer choices for each citing text. The correct answer is the holding statement that corresponds to the citing text. The four incorrect answers are other holding statements. You should find the correct option. There is a <HOLDING> token in the position of the citing text prompt where the holding statement was extracted.

Q: 563 U.S. 421, 438, 131 S.Ct. 1866, 179 L.Ed.2d 843 (2011). Nonetheless, the District Court and the Plan have cited to the language in the Summary Plan Description (“SPD”) as the language of the Plan. We, too, adopt this approach. See US Airways, Inc. v. McCutchen, 569 U.S. 88, 133 S.Ct. 1537, 1543 n.1, 185 L.Ed.2d 654 (2013) ("Because everyone in this case has treated the language from the summary description as though it came from the plan, we do so as well.”). Moreover, insofar as McLaughlin and J.J.M. now contend that the SPD was not "designated a plan document” and so cannot control here, McLaughlin Reply Br. 1, we deem this argument forfeited because it is raised solely in the reply brief. See Laborers' Int'l Union of N. Am. v. Foster Wheeler Corp., 26 F.3d 375, 398 (3d Cir. 1994) (<HOLDING>). 4 . We have considered McLaughlin's and 
 Holding statements: (A) holding an argument not raised in opening brief is waived (B) holding that a party waives an argument that it raises in the background section of its brief but not in the argument section (C) holding argument waived for failure to raise it in opening brief (D) holding that argument not raised in opening brief is waived (E) holding that an argument is not preserved unless a party raises it in its opening brief

A: (E)
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Q: as late as February 1994, although the wife stated that she did not think that she lived with them for longer than one year. The wife testified that, during the time that she lived with the husband’s parents, they helped her financially. It appears that the trial court may have considered the husband’s obligation to support the wife suspended during the time that she lived with his parents, as the order reflects that it calculated arrearage beginning in February 1994. Alimony arrearage is a final judgment as of the date due and is not subject to modification. Harris v. Harris, 553 So.2d 129 (Ala.Civ.App.1989). In some instances alimony obligations can be satisfied by means other than direct payment from the husband to the wife. See, Swindle v. Swindle, 429 So.2d 601 (Ala.Civ.App.1983) (<HOLDING>); Frazier v. Frazier, 455 So.2d 883 
 Holding statements: (A) holding that the proceeds of a liability insurance policy were not property of the estate (B) holding that insurance obligation was primary to indemnity obligation (C) holding that the standard fire policy and a broader homeowners policy were so intertwined that the prescriptive period in the standard fire policy applied to nonfire perils (D) holding that obligation to pay mortgage on home was satisfied by payment of fire insurance proceeds where husband maintained fire insurance policy (E) holding that when the house  is destroyed by fire and there exists thereon a policy by insurance the money arising therefrom stands in the place instead of such house  the proceeds of the policy therefore take the place of the property loss

A: (D)
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Q: of an ex parte injunction were the threatened loss of inventory/goods and the improper dissipation of Playcom’s assets. Such injuries fail to qualify as irreparable harm since they are capable of being quantified for the purpose of imposing an award of money damages. Haitian’s filings indicate that the instant controversy is basically a financial dispute between Haitian and his daughter concerning the dissolution of their Playcom business. Haitian’s pleadings do not set forth any allegation of an imminent harm such as a breach of an enforceable restrictive covenant or a misappropriation of trade secrets or customer lists. Therefore, the trial court’s ex parte injunction order must be stricken. See Jefferies & Co., Inc., v. Int’l Assets Holding Corp., 830 So.2d 256 (Fla. 5th DCA 2002)(<HOLDING>). The temporary injunction order is STRICKEN. 
 Holding statements: (A) holding that trial court erred in granting ex parte temporary injunction prohibiting marketing activities of defendant company because there had been no showing that plaintiff company would likely suffer irreparable harm or lacked an adequate remedy at law (B) holding in part that the trial court abused its discretion in granting a temporary injunction in the absence of a showing that the plaintiff did not have an adequate remedy at law (C) holding that trial court did not abuse its discretion by granting such a temporary injunction (D) holding that temporaryinjunction orders simple recitation of conclusory statement that plaintiff will suffer an irreparable injury for which it has no other adequate legal remedy does not satisfy rule 683s requirement that a temporary injunction order specify reasons why plaintiff will suffer irreparable harm for which there is no adequate remedy at law (E) holding that a movant for a preliminary injunction must first demonstrate that it is likely to suffer irreparable harm in the absence of the requested relief

A:
(A)
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