The following excerpt is from Marsh v. J. Alexander's LLC, 905 F.3d 610 (9th Cir. 2018):
duties" (internal alteration omitted) ); Flood v. Carlson Rests. Inc. , 94 F.Supp.3d 572, 583 (S.D.N.Y. 2015) (explaining that "district courts across the country have likewise endorsed the twenty percent rule").
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