My original complaint to the Pension Ombudsman back in 2001 did indeed try to argue that pension increases were a reasonable expectation (though this was only a minor part of the complaint - most of it centered on IBM's use of the then C Plan surplus to subsidise its M Plan contributions). The main argument against 'reasonable expectation' was that IBM continuually and repeatedly said that the increases were ex gratia and back then it deliberately made them at odd intervals to emphasise this.