Two shareholders of five SEI funds brought a derivative action against the funds’ investment adviser, SEI Investments Management Corporation (“SIMC”), in the United States District Court for the Eastern District of Pennsylvania alleging that the adviser breached its fiduciary duty under Section 36(b) of the 1940 Act by delegating most of its investment management duties to sub-advisers while retaining a substantial amount of the investment management fees it received from the funds. Plaintiffs also allege that SIMC failed to pass along to the funds savings arising from economies of scale. Similar claims alleging violations of Section 36(b), focusing on the differential between the advisory fees paid to the adviser and the sub-advisory fees paid by the adviser to sub-advisers, have been raised in several recent cases, including those brought against The Hartford, AXA, The Principal, Russell, and ING.