In Walsh v. IKON Office Solutions, Inc. (2007) 148 Cal.App.4th 1440, two account managers filed a class action against their former employer, IKON Office Solutions. IKON had classified the account managers as exempt from overtime wage laws under the outside salesperson exemption. This exemption requires that the employees spend more than half of their work time outside the work place. (Walsh, supra, at p. 1455.) IKON moved to decertify the account manager subclass, contending that common questions of law and fact did not predominate over individual issues. It argued that the account manager positions were designed to be outside sales positions in which account managers were paid a commission on their transactions. Their performance was determined by sales quotas and accomplishing specific sales activity requirements. (Walsh, supra, 148 Cal.App.4th at p. 1454.) IKON presented evidence that the performance of the managers' primary functions varied significantly, depending upon territory, number of customers, job orders, support from customer service representatives and the personal approach of each manager. (Ibid.) The trial court granted the motion, noting that individualized analyses of each subclass members' work circumstances would be required. As a result, individual hearings on both liability (time spent on exempt versus nonexempt tasks) and damages (number of overtime hours worked) would be necessary for each of the class members. (Walsh, supra, 148 Cal.App.4th at p. 1452.) The reviewing court determined that the trial court's order was supported by substantial evidence. (Id. at p. 1456.)