The following excerpt is from Van Lith v. Iheartmedia + Entm't, Inc., Case No. 1:16-cv-00066-SKO (E.D. Cal. 2017):
"Nevertheless, named plaintiffs, as opposed to designated class members who are not named plaintiffs, are eligible for reasonable incentive payments." Id. at 977. However, "district courts must be vigilant in scrutinizing all incentive awards to determine whether they destroy the adequacy of the class representatives." Radcliffe v. Experian Info. Sols. Inc., 715 F.3d 1157, 1164 (9th Cir. 2013).
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