In Wilder v. May Dept. Stores Co. (23 AD3d 646 [2d Dept 2005]), the Court held that class action treatment was appropriate as to claims by employees against department stores which the employees sought recovery of amounts deducted from the individual sales receipts upon which their commissions were calculated. The amounts so deducted reflected an apportioned share of so-called "unidentified returns," i.e., merchandise returned to a store by a customer without documentation identifying any particular salesperson as having generated the sale. However, the Court did not address whether any administrative remedy was available and, if so, whether that remedy was preferable to class action certification.