A federal district court judge in New York held that sales representatives working for Novartis Pharmaceuticals Corp. are exempt from overtime pay under the outside sales and administrative exemptions under the federal Fair Labor Standards Act (FLSA), as well as under California and New York wage and hour laws. Novartis' sales representatives visit doctors to educate them about the company's products and receive commissions tied to the number of prescriptions written by doctors within the sales representative's assigned territory. Ruling for the company, the court found that the sales representatives came under the outside sales exemption even though they did not (and could not) make sales directly to the doctors they visited. The court considered the unique characteristics of the pharmaceutical industry and found that by educating the doctors about the products and urging them to write prescriptions when suitable to address patients' needs, the sales representatives could be considered to be making sales within the context of the pharmaceutical industry. The court also found that the sales representatives were covered under the administrative exemption because they performed work that is ancillary to production, directly related to the company's general business operations, and also used discretion and independent judgment in their interactions with doctors by tailoring their presentations with the goal of increasing the number of prescriptions written for the drug.