Within the last several months, we reported on an important Court of Appeals decision involving the issue of whether the Fair Labor Standards Act's (FLSA's) outside sales exemption applies to pharmaceutical sales representatives. As there was a split in authority, it is not surprising that the U.S. Supreme Court in late November accepted the case to consider that issue as well as the issue of whether deference is owed to the Secretary of Labor's interpretation of the outside sales exemption under the FLSA and related regulations. As these pharmaceutical sales persons are not involved in direct sales, this will be an important decision when rendered. Christopher v. SmithKline Beecham Corp., (9th Cir. 2011), certiorari granted.