This case involves unpaid sales commissions for a salesman who quit. The plaintiff worked at a magazine and was in charge of selling ad space to different companies. The magazine, however, was barely breaking even, and instated new policies of unpaid training periods while reducing the amount of commissions being paid to their sales agents. Eventually, the magazine put a three-month freeze on commissions paid to agents, delaying payment until the magazine was in a better financial state. The plaintiff quit his job and brought suit against the magazine for unpaid commissions; at the time of the trial, the company had been additionally sued by a past intern who alleged that the company’s wage policies resulted in an unpaid internship with unreasonable hours.