Note K   Commitments and Contingencies Total rental expense for operating leases, principally for administrative and sales office space, was $14.1 million, $12.7 million and $11.0 million for the years ended December 31, 2010, 2009, and 2008, respectively. As of December 31, 2010, future net minimum rental payments under non-cancelable operating leases were approximately $68.6 million, payable as follows: 2011   $15.2 million, 2012   $14.0 million, 2013   $13.1 million, 2014   $11.3 million and $15.0 million thereafter. A putative class action, Moore v. Reliance Standard Life Insurance Company, was filed in the United States District Court for the Northern District of Mississippi in July 2008 against the Company s subsidiary, RSLIC. The action challenges RSLIC s ability to pay certain insurance policy benefits through a mechanism commonly known in the insurance industry as a retained asset account and contains related claims of breach of fiduciary duty and prohibited transactions under the federal Employee Retirement Income Security Act of 1974. The parties have entered into an agreement to settle this litigation, which is subject to the approval of the court, and have filed a motion with the court seeking such approval. It is not anticipated that this settlement, if approved and effectuated, will have a material adverse effect on the Company s results of operations, or liquidity financial condition. In addition to this action, the Company is a party to various other litigation and proceedings in the course of its business, primarily involving its insurance operations. In some cases, these proceedings entail claims against the Company for punitive damages and similar types of relief. The ultimate disposition of such litigation and proceedings is not expected to have a material adverse effect on the Company s results of operations, liquidity or financial condition.