D'EstE

MEMORANDUM

In these three consolidated cases, pharmaceutical sales representatives Gina D’Este, William Barnick, and Roxana Menes (“Plaintiffs”) appeal the district courts’ decisions granting summary judgment to Defendants Bayer Corporation, Wyeth Pharmaceuticals, and Roche Laboratories, Inc., with respect to Plaintiffs’ claims for unpaid overtime wages under California Labor Code § 510. We have jurisdiction pursuant to 28 U.S.C. § 1291 , and we affirm on the ground that Plaintiffs fall under the “administrative” exemption to California’s overtime wage requirements. See Cal. Labor Code § 515 (a); CaLCode Regs. tit. 8, § U040(1)(A)(2).

First, Plaintiffs’ duties involved “[t]he performance of ... non-manual work directly related to management policies or general business operations” of their employers. CaLCode Regs. tit. 8, § 11040(l)(A)(2)(a)(U (2001); see also 29 C.F.R. § 541.205 (2001). Their work was “qualitatively” administrative because they were involved in representing their respective companies and promoting sales of prescription drugs within their assigned territories, activities which are characterized as exempt under the incorporated federal regulation 29 C.F.R. §…