identical policy language. See Mayhew v. Hartford Life & Accident Ins. Co., 2011 WL 5024648, at *5–7 (N.D.Cal. Oct. 21, 2011) (denying insured's motion to dismiss plan's counterclaim because dependent Social Security disability benefits could be offset against insured's long-term disability benefits pursuant to policy language permitting offset of “loss of income” benefits paid to insured or insured's family under Social Security Act); Fortune v. Group Long Term Disability Plan for Employees of Keyspan Corp., 588 F.Supp.2d 339, 341–42 (E.D.N.Y.2008) (denying insured's motion to amend complaint as futile because plan's language offsetting “loss of income” benefits provided to insured or her family because of the insured's disability would permit offset of dependent Social Security disability benefits), aff'd, 391 Fed.Appx. 74, 80 (2d Cir.2010); Pennell v. Hartford Life & Accident Ins. Co., 2010 WL 330259, at *5–7 (N.D.Ohio Jan. 21, 2010) (same, under arbitrary and capricious standard); Kennedy v. Hartford Ins. Co., 2009 WL 3007921, at *4–5 (E.D.N.Y. Sept. 21, 2009) (same, under arbitrary and capricious standard), aff'd, 402 Fed.Appx. 610 (2d Cir.2010). We find no meaningful basis on which to distinguish the phrase “loss of income” interpreted in these cases from the phrase “loss of time” used in the plans at issue here.