In Bradley v. Networkers Internat., LLC (2012) 211 Cal.App.4th 1129, the plaintiffs sought to certify a class of telecommunications technicians whose job duties were similar (if not identical) to the duties of the purported class members at issue in this case. The defendant, Networkers International, contracted with "telecommunication companies ... to supply skilled laborers to install and service cell sites in Southern California." (Id. at p. 1134.) To fulfill these contracts, Networkers retained approximately 140 "field technicians" to "provide repair and installation services at the cell sites." (Id. at pp. 1139, 1134.) Each technician was required to sign a standardized "Independent Contractor Agreement" containing language reflecting an independent contractor relationship. Because Networkers characterized the technicians as independent contractors, it "did not pay premium wages for overtime ... or establish a policy requiring meal or rest breaks." (Id. at p. 1135.) At some point in 2005, Networkers reclassified its technicians as employees and began paying them overtime; the company did not, however, implement a meal or rest break policy. In 2006, the plaintiffs filed a class action alleging Networkers violated wage and hour laws by, among other things, failing to pay overtime and failing to adopt a policy providing its technicians rest and meal breaks. In support of their motion for certification, the plaintiffs submitted numerous class declarations asserting that the technicians' job duties and working conditions differed substantially from the job description set forth in Networkers's standardized "Independent Contractor Agreement." Each declarant also denied having been paid overtime or receiving meal or rest breaks. In addition to the declarations, the plaintiffs submitted discovery responses in which Networkers admitted that (1) it did not pay overtime to its technician members until the 2005 reclassification; (2) it did not have a rest or meal break policy or maintain records of rest or meal breaks; and (3) because it did not supervise its technicians, it did not know whether the workers took rest or meal breaks, nor did it know the extent or frequency of such breaks. (Bradley, supra, 211 Cal.App.4th at p. 1140.) The trial court denied certification for two reasons. First, it explained that individual issues predominated as to whether each class member qualified as an independent contractor. (Bradley, supra, 211 Cal.App.4th at p. 1140.) Second, the court concluded that certification was improper because, to establish Networkers's liability, each technician would have to individually demonstrate "'the actual existence of damages and/or the manner of incurring damages.'" (Ibid.) In its initial (now vacated) opinion, the Court of Appeal affirmed, ruling that although substantial evidence did not support the trial court's finding that individual issues would predominate the question whether class members qualified as independent contractors, "there were reasonable grounds for the trial court to conclude that ... determining the existence and amount of damages for each class member" would require individual inquiry into "which employees had missed breaks ... and whether those missed breaks were the result of Networkers's lack of a break policy." (Id. at pp. 1145, 1151 explaining reasoning set forth in its vacated opinion.) On remand from the Supreme Court, however, the Court of Appeal concluded that, under the analysis set forth in Brinker, the trial court had improperly focused on individual issues related to damages, rather than on the plaintiffs' theory of liability. (Bradley, supra, 211 Cal.App.4th at p. 1151.) According to the court, Brinker had clarified that "in ruling on the predominance issue in a certification motion, the court must focus on the plaintiff's theory of recovery and assess the nature of the legal and factual disputes likely to be presented and determine whether individual or common issues predominate." (211 Cal.App.4th at p. 1150.) The court further explained that "plaintiffs' theory of recovery was based on Networkers's (uniform) lack of a rest and meal break policy and its (uniform) failure to authorize employees to take statutorily required rest and meal breaks. The lack of a meal/rest break policy and the uniform failure to authorize such breaks are matters of common proof. Although an employer could potentially defend these claims by arguing that it did have an informal or unwritten meal or rest break policy, this defense is also a matter of common proof." (Id. at p. 1150.) The Court of Appeal concluded that "no aspect of Brinker" had affected its prior conclusion that the legal issue of whether Networkers properly classified its technicians as independent contractors, rather than employees, was susceptible to class treatment. (Bradley, supra, 211 Cal.App.4th at p. 1145.)