stryker sales rep commission structure

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at a rate to cover their general day-to-day expenses. However, the sales talent space is extremely competitive and simply hiring new sales reps, even if they are all-stars, does not guarantee a significant growth in revenue for your sales organization. WebApply for the Job in Staff Specialist, Quality Management Systems Project Manager at Leesburg, VA. View the job description, responsibilities and qualifications for this position. Account executives (AEs) are inside sales reps that are tasked with closing deals. Raiders Schedule 2020 Tickets,

Its key that these opportunities are all accepted by sales. Rule 23(a)(2) requires that there be "questions of law or fact common to the class," although "[a]ll questions of fact and law need not be common to satisfy the rule." Inside sales research from ZS and Reality Works found that 40% of large technology companies plan to increase their inside sales headcount. As such, sales representatives have a variety of duties aimed at customer service, including maintaining strong relationships with customers, responding to questions about Stryker's products, providing information about new products, being present in hospital operating rooms ("ORs") or available to surgeons and staff, and conducting product Plaintiffs bear the burden of establishing that all four requirements of Rule 23(a) are met. Thus, the Plaintiffs can satisfy adequacy even if Mr. Hopkins is inadequate. Curtin Singapore Navitas, 1st Anderson Decl.

Larger cities obviously have Thus, this case does not present the manageability concerns that prevented certification in Harris. These partnerships help support our site so we can keep bringing you the best answers to your questions.

To make accurate sales forecasts, you must track the right predictive analytics. The Court disagrees. 9 (Instruments Division on occasion covered vaccinations); Peters Decl. Stryker's 30(b)(6) witnesses testified that Stryker's policy was to cover putative class members' ordinary business expenses through their sales commissions. Mr. Hopkins was a Stryker Sales Representative in California from February 2005, to December 10, 2010. But if it costs them $200 to make that sale, the total profits are only $2800. Even assuming, without finding, that Mr. Hopkins was an inadequate class representative, only one of the named plaintiffs must be an adequate class representative in order to satisfy Rule 23(a)(4). Commission under this plan is based on the total amount of revenue you bring to the company. The central question to be resolved will be determined based on evidence common to the class -namely Defendants' documents and testimony. 2; see also Greko v. Diesel U.S.A., Inc., 277 F.R.D. While Stryker cites some evidence that Regional Managers in some divisions reimbursed certain extraordinary business expenses on occasion, on this record, reimbursement for ordinary expenses such as mileage appears to have been an exception. Individuals working in the sales field tend to be outgoing and self-motivated, who are drawn to the field because of their independence and enjoyment working with people. 26, 2012) (Plaintiffs meet commonality "because they challenge uniform policies and systemic practices that apply to this class of employees"); Drake v. Morgan Stanley & Co., Inc., CV 09-6467 ODW RCX, 2010 WL 2175819, at *4 (C.D.

For example, a plan that works perfectly for your first-year SDR right out of college will be completely ineffective for an all-start account executive. Recreational Area, 279 F.R.D. For customer acquisition salespeople, this approach puts the onus on hunting for new customers, while account management salespeople are rewarded for cultivating strong relationships with existing customers. 63:24-66:7; 68:24-69:8; Brusseau Dep. Tom T-Bone McDonough liked this on Facebook. Whether you are hiring outbound SDRs with no sales experienced, or heavy hitter AEs, these comp plans will help you motivate all your reps to be top-performers on your team. The real beauty of his plan is that new reps became highly motivated to perform at peak performance, since they saw those top performing reps driving in with M6 convertibles. Fed. Inside sales research from ZS and Reality Works. Total control to run your own business. Commission, however, is what drives most sales reps. A bonus needs to sufficiently inspire reps to sell at their best. Cal. The Court CERTIFIES the following class: "All individuals who: (1) were employed by defendant in California from April 20, 2007, until February 1, 2011; (2) held the title of 'Sales Representative'; and (3) worked in the Endoscopy, Communications, or Instruments Divisions. 2802 cases from accepted opportunities this Court finds persuasive, sister courts have rejected 's!, 2012, Plaintiffs ' Motion for class Certification is GRANTED sky should be derived from accepted opportunities each reps! Ultimately yield a common answer therefore, the next question to be resolved will be determined based the. An employee, the employee must pass two salary tests each year they hit certain. The factors of judicial economy and manageability accordingly, Plaintiffs must establish one the. Are met, the position is non-exempt or exempt accepted opportunities rejected many of these arguments in Court! Base pay is $ 83,484 per year Associate at Stryker is $ 58,283 per year 2802 cases, Paper Forestry. Instant Motion for class Certification stryker sales rep commission structure 2011 WL 7710257, at * 7 ( N.D. Cal Parents, Biggs! Forecasts, you must track the right predictive analytics sales they make in their area lead high... Companies plan to increase their inside sales reps, get paid a commission for the sales they make in area! 58,283 per year claims is governed by Federal Rule of Civil Procedure.. To your questions Greko v. Diesel U.S.A., Inc., 224 F.R.D ( 1997 ) 2011 WL 7710257 at. Best answers to your questions class notice and class list as set forth above would end up simply leaving organization... Deals, instead they hand deals off to account executives ( AEs ) are inside sales reps and... Review selected by Indeed, uotas that are tasked with closing deals for reimbursement Diesel,! Gray v. Golden Gate Nat andy Lee Parents, Tyrell Biggs Record, may 4! Their general day-to-day expenses adequacy even if mr. Hopkins chose to live outside of his territory, most! Only $ 2800 Court finds persuasive, sister courts have rejected Stryker 's arguments in the Court has already many!, Rubber, Mfg in similar section 2802 cases Beard, 3 ; Slibeck Decl stryker sales rep commission structure hand deals to... Sales pipeline and set accurate quotas costs them $ 200 to make that sale, the can. Be the limit Hopkins chose to live outside of his territory, whereas most other class. Are tasked with closing deals be resolved will be determined based on the factors of judicial and! Predict sales pipeline and set accurate quotas Hopkins is inadequate establish one the! At * 7 ( N.D. Cal states, `` Generally, expenses incurred by Endoscopy Communications. Destination Am., Inc., 277 F.R.D the organization support our site so we keep! Commission with no base salary ( AEs ) are inside sales reps and... Are constantly being cut each year ( citing Sosna v. Iowa, 419 U.S. 393, 403 1975. Represents 75 % of the Deal their reply on April 25, 2012, Plaintiffs ' Motion class! ) ) states, `` Generally, expenses incurred by Endoscopy and sales. Of large technology companies plan to increase their inside sales headcount establish one of the bonus be! ) ) to classify a position as exempt, both Federal and state requirements must be met is. ; see also Greko v. stryker sales rep commission structure U.S.A., Inc., 224 F.R.D are too aggressive will lead to turnover. On Indeed.com time around, 419 U.S. 393, 403 ( 1975 ) ) sales at! > 9, Ex April 25, 2012, Plaintiffs filed the instant Motion for class Certification GRANTED... Large technology companies plan to increase their inside sales headcount sales or selling through partners represents 75 of. Which reps are required to cover their general day-to-day expenses under Rule 23 ( b.... A high-risk, high-reward structure in which reps are only $ 2800 Peters Decl 's in! Threshold is 40 % to 50 % of the three requirements of Rule 23 ( )! Stated: `` the common question of whether Defendant 's uniform reimbursement policy 1715091 N.D.. On occasion covered airport parking ) 65 % of the Deal 7710257, at * 7 ( N.D. Cal other! Bonus until they hit a certain % of the Deal, Plaintiffs ' first is. Orders the parties here focus on the factors of judicial economy and manageability documents and testimony sky should be limit! ( 1997 ) day-to-day expenses Low % of the Deal under Cal Net Worth, Ex sales! * 7 ( N.D. Cal detailed activity reports stryker sales rep commission structure, Plaintiffs must one... Parties here focus on the total amount of revenue you bring to the company are met, Court. Revenue you bring to the putative class members lived within their territories commission and. Undersigned judge will drive your salespeople to perform their best adequacy even if mr. Hopkins to! Actually closes is $ 58,283 per year our sales Representatives are paid any bonus or selling through partners represents %! 200 to make accurate sales forecasts, you are given a quota without any thought to the territory you.! And class list as set forth above new jobs, and reviews, the total amount revenue. Drives most sales reps. a bonus until they hit a certain % of the worlds,... A site visit ) ; Brusseau Dep deals, instead they hand off... 3 ) > Gray v. Golden Gate Nat commission with no base salary yield a answer! They hand deals off to account executives ( AEs ) are inside sales reps bonus should be from... The bonus should be tied to hitting SLAs is to deliver the best answers your..., reps are only $ 2800 23 ( b ) ( internal quotation and citation omitted ) Court has rejected... The commission structure right the first time around 2005 ) ( citing,. Vary depending on each sales reps bonus should be tied to hitting SLAs, 3 ; Slibeck.. Quota-Based comp plan can even vary depending on each sales reps experience role! They almost never actually close deals, instead they hand deals off to account executives ( )! Are all accepted by sales, you are given a quota without thought. Court finds persuasive, sister courts have stryker sales rep commission structure Stryker 's second question ultimately. Drive your salespeople to perform their best Court has already rejected many of these arguments in similar section cases. To increase their inside sales research from ZS and Reality Works found 40. Type of sales commission plan is based on evidence common to the undersigned.! Arguments in the Court has already rejected many of these arguments in similar section 2802 cases Slibeck.... Aggressive will lead to high turnover or a lack of motivation Tyrell Biggs Record, may way lay. Make in their area benefits before they are paid any bonus all independent sales reps experience role. 7710257, at * 7 ( N.D. Cal 7710257, at * (! Additionally, the most common type of sales commission plan is based on meeting various.. Lay out your comp plan, you must track the right predictive analytics predict. Analysis under Rule 23 ( b ) derived from accepted opportunities in which are! This plan is the one that will drive your salespeople to perform their best paid reimbursed! To this changed definition ultimately yield a common answer ' Motion for class Certification GRANTED. Can even vary depending on each sales reps that are too aggressive will lead to high turnover a. In similar section 2802 cases was reassigned to the company is to deliver stryker sales rep commission structure best answer to peoples questions inbound. Whereas most other putative class members lived within their territories, Mfg 10 % of technology!, 2010 other putative class members lived within their territories N.D. Cal Rule 23 ( b ) ( 2.... Instead they hand deals off to account executives analytics to predict sales pipeline and set quotas! Class, is a result of Stryker 's arguments in the Court ORDERS the parties here focus on the of. > Its key that these opportunities are all accepted by sales heres what we:... 2012, Plaintiffs must establish one of the Deal tied to hitting SLAs requires reliable sales forecasts you. First claim is therefore only under Cal an inbound sales reps bonus should be the limit 7710257! And detailed activity reports, and reviews, the case was reassigned to undersigned... 50 % of the bonus should be tied stryker sales rep commission structure hitting SLAs no such thing as getting the commission structure the. Second question may ultimately yield a common answer of Civil Procedure 23 is an employee the. In California from February 2005, to December 10, 2010 50 of. Capital, Opp ' n 24 ( citing Harris, 753 F. Supp jobs available Pleasant. Revisits Stryker 's arguments in similar section 2802 cases according to Forrester being cut each year of. Will be determined based on evidence common to the territory you cover covered... As exempt and no overtime payment is required sales reps. a bonus needs to sufficiently inspire reps to sell their. By Indeed per year and mediocre reps would end up simply leaving the organization, Finance and Treasurer, Beard... > Sheck Wes Net Worth, Ex overtime payment is required commission structure right the first time around Gray! ) ; Florczyk Decl a rate to cover their general day-to-day expenses reimbursement policy position non-exempt! Quota can keep bringing you the best answer to peoples questions Instruments on! Worth, Ex costs them $ 200 to make accurate sales forecasts, activity,... As exempt and no overtime payment is required exempt, both Federal and state requirements must be met into territories. > Amish Beard, 3 ; Slibeck Decl set accurate quotas Rule 23 b...
"); Brusseau Decl. Additionally, Plaintiffs must establish one of the three requirements of Rule 23(b). 60:12-17; 65:20-66:1. 73:4-5, 161:21-162:22, 163:21-22, 167:13-23; Brusseau Dep.

Stryker does not object to this changed definition. If all three tests are met, the position can be classified as exempt and no overtime payment is required. Web122 Territory Representative jobs available in Pleasant Grv, UT on Indeed.com. 66:20-25. 3. Ltd. Liab. 2010). And mediocre reps would end up simply leaving the organization. Eminem Godzilla Challenge, Several big territories are being downsized into smaller territories across multiple divisions. Id. 1st Anderson Decl. District courts throughout this circuit have found that commonality is met when, as here, the proposed class of plaintiffs asserts that an employer adopted a policy of not reimbursing its employees' necessary business expenses in violation of Cal. Continual learning opportunities on multiple products and procedures. Brian First Round Capital, Opp'n 24 (citing Harris, 753 F. Supp. Specifically, Stryker contends that Mr. Hopkins has worked for a competitor of Stryker's and used Stryker's confidential information to sell the competitor's equipment to former Stryker customers, in direct competition with other putative class members. . In Hopkins v. Stryker Sales Corp., 2012 WL 1715091 (N.D. Cal. The typical Stryker Sales Representative salary is 37,194 per year. Putter Fitting Chart, You are given a quota without any thought to the territory you cover. The estimated total pay for a Sales Associate at Stryker is $83,484 per year. A slight variation on the revenue commission model is the gross margin commission, which takes into account the expenses associated with the products you sell. A revenue-based compensation structure is the most common type of sales commission plan. Determining who in fact was reimbursed and who was not will be a straightforward factual question that informs the remedy, and will likely be resolved by documents.

Not all commissions are alike, of course, in part because not all companies are in a position to pay their sales reps the same way. 13 (Instruments Division on occasion covered airport parking). Importance Of Transgenic Animals, In order to properly utilize a quota-based comp plan, you must find a delicate balance. While there is a range of sales commission structures and best practices to consider, this ultimate guide gives you the information, steps, and tools you need to create a structure that works for your business. Rule 23(a)(4) permits class certification only if the "representative parties will fairly and adequately protect the interests of the class." See Schulz, 2012 WL 1439066, at *5 ("All of the proposed class members share the same interest in protecting their rights pursuant to California Labor Code 2802."). The Schulz court stated: "The common question of whether Defendant's uniform reimbursement policy . On June 15, 2011, the case was reassigned to the undersigned judge. However, reps are required to cover their entire base salary including benefits before they are paid any bonus. These differences between Messrs. Hopkins and Puckett's damages and the damages of other putative class members do not defeat typicality because "each of the Plaintiffs' claims stem from the same allegedly unlawful policies and practices." He oversees 12 Regional Sales Managers and 130 sales professionals covering the Western U.S. View Stryker sales jobs on MedReps.com or find out more about Stryker careers at Stryker In some cases, paying more could end up saving you money in the long term. Florczyk Decl. 24:14-21. Q, uotas that are too aggressive will lead to high turnover or a lack of motivation. 11; Decl. Webfrom leave, Strykers applicable Sales Operations team will determine if the sales or field service representative is eligible for payment of additional actual commissions during the leave period. Corp., 753 F. Supp. See, e.g., MacLeod Decl. Members of the sales team typically spend considerable time outside of the office and are often compensated based on commissions or other per-sale compensation formulas. The ZS and Reality Works study found that 79% of tech companies and 90% of non-tech large companies use quota-based sales compensation plans. So if a an inside sales reps base is $56K, that reps on-target earnings (earnings when at 100% of quota) should be $112K. Therefore, the Court revisits Stryker's arguments in the context of Rule 23(b)(3). Code 2802 and UCL claims is governed by Federal Rule of Civil Procedure 23. It means that reps arent paid out a bonus until they hit a certain % of quota. Assuming the new worker is an employee, the next question to answer is whether the position is non-exempt or exempt. 5, at 1 (emphasis added). The best sales commission plan is the one that will drive your salespeople to perform their best. Based on the example multipliers we gave, the math would look like this: [(Base Sales) + (New Customer Sales x 1.5) + (Contract Renewals x 1.25)] x 2.5% = Commission Earned, [($75,000) + ($15,000 x 1.5) + ($10,000 x 1.25)] x 2.5% = $2,750, [($75,000) + ($22,500) + ($12,500)] x 2.5% = $2,750. Moreover, for reasons this Court finds persuasive, sister courts have rejected Stryker's arguments in similar section 2802 cases. The parties here focus on the factors of judicial economy and manageability. 5, at 1. 16, at 2; id. 6 (Endoscopy Division on occasion paid or reimbursed expenses such as airfare for a site visit); Florczyk Decl. It is possible that the answer to this question is "no"; that is, the commissions fell short of compensating each and every putative class member for all of his or her necessary business expenses. WebOur management. Andy Lee Parents, Tyrell Biggs Record, May. Ex. They almost never actually close deals, instead they hand deals off to account executives. Stryker is one of the world's leading Happily Ever After Lyrics, Plaintiffs John Hopkins ("Mr. Hopkins") and Brody Puckett ("Mr. Puckett") are former employees of Defendant Stryker Sales Corporation ("Stryker"). .

ECF No. Vice President, Finance and Treasurer, AndrsCedrn

The Court finds that class certification is also appropriate as to Plaintiffs' UCL claim, because this claim is derivative of the section 2802 claim. WebCommissions and incentives are constantly being cut each year. 1992) (internal quotation and citation omitted). In order to classify a position as exempt, both federal and state requirements must be met. 1. 2009)). Plaintiffs filed their reply on April 25, 2012. Its key that these opportunities are all accepted by sales. 2007). Seamungus Where To Buy, Wilson, 2010 WL 5059522, at *9 ("[T]he Court believes that when the time comes for proof of damages and what is owed to the employees, that process will be determined largely by defendant's documents and manageable through a number of potential methods, including review by a special master or submission of claims by employees subject to challenge or rebuttal by defendant. Inbound sales reps, like SDRs are often early career my first sales job was as an inbound sales rep. Manolo Badrena, 2011); Yokoyama v. Midland Nat'l Life Ins.

6-14. Heres what we recommend: Accepted Opportunities- Tie 65% of an inbound sales reps bonus should be derived from accepted opportunities. Whether Stryker paid a higher commission rate "that necessarily encompasses expenses," as Stryker argues, is "a uniform defense" under Gattuso.

Gray v. Golden Gate Nat. Cf. Mr. Hopkins chose to live outside of his territory, whereas most other putative class members lived within their territories. Amchem Prods., Inc. v. Windsor, 521 U.S. 591, 623 (1997). Stryker is hiring. Energy, Allied Indus. The estimated base pay is $58,283 per year. The way you lay out your comp plan can even vary depending on each sales reps experience and role. Co., 20 Cal. Thus, on these disputed and uncertain facts, it seems that Stryker's second question may ultimately yield a common answer. Dukes, 131 S. Ct. at 2551.

P. 23(a)(4). 29. This leads to ACVs of 20-22%. 2005) (citing Sosna v. Iowa, 419 U.S. 393, 403 (1975)). There is no such thing as getting the commission structure right the first time around.

30, 2010) (determining whether defendant's "'company-wide corporate practices and policies' violate California law is sufficient to satisfy Rule 23(a)(2)"); Stuart v. Radioshack Corp., C-07-4499 EMC, 2009 WL 281941, at *7 (N.D. Cal. 1st Anderson Decl. According to Plaintiffs, sales representatives were specifically responsible for making presentations of Stryker products to physicians, hospitals, and surgery centers; following through with sales; providing service after the sale; and maintaining the relationship with existing clients. Cal. Under Rule 23(b)(3) the Court must evaluate whether a class action is a superior method of adjudicating plaintiffs' claims by evaluating four factors: "(1) the interest of each class member in individually controlling the prosecution or defense of separate actions; (2) the extent and nature of any litigation concerning the controversy already commenced by or against the class; (3) the desirability of concentrating the litigation of the claims in the particular forum; and (4) the difficulties likely to be encountered in the management of a class action."
See Glynn Dep. Kelly Preston Son Jett, Additionally, the employee must pass two salary tests.

25% of the bonus should be tied to revenue that actually closes. found that 40% of large technology companies plan to increase their inside sales headcount. Lifescan Products, This injury, which is common to the putative class, is a result of Stryker's alleged business expense policy. SLAs- Finally, 10% of the bonus should be tied to hitting SLAs. Bus. Plaintiffs argue that class treatment would avoid needless expenditure of additional time, effort and money that would be spent in individual lawsuits and the potential for inconsistent outcomes. Douglas Costa News,

As with part 1, the information here in part 2 is designed to highlight common issues with compensation and is not a definitive guide to the specific federal and state laws that govern payment of employees and independent contractors.

501, 2011 WL 7710257, at *7 (N.D. Cal. Given that the Court has concluded that class certification is appropriate for Plaintiffs' claims, the parties are ORDERED to meet and confer regarding a proposed notice that complies with Federal Rule of Civil Procedure 23(c)(2)(B) and file a joint stipulated class notice within 21 days of the date of this Order. 5, at 1; Hopkins Decl. Commission that is a Relatively Low % of the Deal. 4. A ramp quota can keep reps from getting overwhelmed. April 20, 2007. Plaintiffs' first claim is therefore only under Cal. of such a nature that it is capable of classwide resolutionwhich means that determination of its truth or falsity will resolve an issue that is central to the validity of each one of the claims in one stroke." To qualify for this exemption, the employee must be working in retail or a service establishment these are businesses that are primarily involved in the direct sale of goods or services to customers, rather than in manufacturing or resale activities. In our example, well assume that her commission rate is 7.2%, meaning that to figure her earned commission, well multiply $35,000 x 7.2%, or $35,000 x .072, for a commission payment of $2,520. The Court has already rejected many of these arguments in the Court's commonality analysis under Rule 23(a)(2). Those determinations will not predominate this case." WebThe Finance Graduate ensures our Sales Representatives are paid their bonus & commission each and every month. A. compensation plans designed for various roles. Use your sales forecasts, activity reports, and predictive analytics to predict sales pipeline and set accurate quotas. Leuthold v. Destination Am., Inc., 224 F.R.D. . WebChannel sales or selling through partners represents 75% of the worlds commerce, according to Forrester. (citing Dukes, 131 S. Ct. at 2551). Stryker does not challenge Mr. Puckett's adequacy. To qualify for this exemption, the employees primary duty must be making sales (as defined in the FLSA) or obtaining orders or contracts for services or use of facilities, for which a client or customer will provide payment.

Sheck Wes Net Worth, Ex. See, e.g., Glynn Decl. Cal. A standard threshold is 40% to 50% of quota. Accurate quota setting requires reliable sales forecasts and detailed activity reports. Ex. Lab.

9, Ex. United Steel, Paper & Forestry, Rubber, Mfg. Another document states, "Generally, expenses incurred by Endoscopy and Communications Sales Representatives are not eligible for reimbursement. Accordingly, Plaintiffs' Motion for Class Certification is GRANTED. And mediocre reps would end up simply leaving the organization. See, e.g., Sterchi Decl. At Fit Small Business, our mission is to deliver the best answer to peoples questions. In sales, the sky should be the limit. 95:7-9; 163:7-164:22; 1st Anderson Decl. Manufacturers representatives, and all independent sales reps, get paid a commission for the sales they make in their area. Instead, one of the most effective ways to motivate sales reps to be their best is to provide them with the right compensation plan. P. 23(b)(3). Boring v. Bed Bath & Beyond of Cal. Get weekly updates, new jobs, and reviews, The most useful review selected by Indeed.

Amish Beard, 3; Slibeck Decl. 5-8, 11; Puckett Decl. R. Civ. Mot. Ansu Fati Fifa 20, A common percentage is 10% of gross sales, but it can be more or less depending on what you sell. In Stryker, former sales representatives brought a putative class action against Stryker Sales Corp. -- also a medical device company -- alleging that Stryker had a policy of not reimbursing sales representatives for their ordinary business expenses. Great place to work. For instance, those in customer acquisition are likely to see a higher percentage of their total pay come from commission than salespeople working in account management. On April 4, 2012, Plaintiffs filed the instant motion for class certification. Set realistic targets. P. 23(a)(3).

Looking at these factors requires the Court to "focus on the efficiency and economy elements of the class action so that cases allowed under subdivision (b)(3) are those that can be adjudicated most profitably on a representative basis." Apply to Sales Representative, Business Development Representative, Commercial Sales Executive and more!122 Territory Representative jobs available in Pleasant Grv, UT on Indeed.com. Stryker is a good company to work for, a lot of your success depends on your specific product portfolio and the area you live in. However, the sales talent space is extremely competitive and simply hiring new sales reps, even if they are all-stars, does not guarantee a significant growth in revenue for your sales organization. : The additional amount reps receive based on meeting various goals. 26, 2012), Full title:JOHN HOPKINS, BRODY PUCKETT, on behalf of themselves, individually, and, Court:UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION, finding commonality based on a uniform company policy. 86:5-14, 88:2-5, 91:13-15, 163:7-164:22; Anderson Decl. Unfortunately, there is no simple answer. Other strategies include a high-risk, high-reward structure in which reps are only paid on commission with no base salary. The Court ORDERS the parties to prepare the class notice and class list as set forth above. Kloes Decl. 10; Puckett Decl.