Is there a conflict of interest in awarding compensation to a class representative in a class action?

Although incentive awards are "fairly typical in class actions," Rodriguez, 563 F.3d at 958, they "should not become routine practice," lest the representatives be "tempted to accept suboptimal settlements at the expense of the class members whose interests they are appointed to guard." Radcliffe v. Experian Information Solutions Inc., 715 F.3d 1157, 1163 (9th Cir. 2013) (internal quotation marks and citations omitted). The potential conflict between the representative and the class is exacerbated when, as here, there is a large difference between the requested incentive award and individual class member recovery. See id. at 1165. Accordingly, "courts must be vigilant in scrutinizing all incentive awards to determine whether they destroy the adequacy of the class representatives." Id. at 1164.