Burlington forced Gallano, one of its check-out clerks, to sign a promissory note for losses on return of items by customers or mistaken pricing of goods due to other workers’ errors in affixing price tags.  This opinion holds that Gallano stated viable claims against Burlington for violation of Lab. Code 2802 (which requires the employer to reimburse employees for expenses or losses incurred during performance of work duties), for violation of the UCL and for declaratory relief, but not for violation of an IWC work order or Lab. Code 1198.  The decision distinguishes USS-Posco Industries v. Case (2016) 244 Cal.App.4th 197, which involved an employee voluntarily incurring an obligation to pay for entirely optional training.  Here, Gallano did not voluntarily incur the losses or sign the promissory note.  The decision also rejects Burlington’s argument that Gallano could not invoke section 2802 because she hadn’t paid out any money.  It points out that by siging the promsisory note plaintiff incurred a loss, which is enough to trigger the statute’s protections.  That loss was also sufficient economic injury to support UCL standing.  Burlington’s post-suit waiver of the note and any right to collect it was a failing effort to pick off a class action plaintiff.  Gallano stated a viable claim for declaratory relief invalidating the promissory note.  However, there is no independent private right of action under Labor Code 1198 which merely authorizes IWC orders.  Violation of an IWC order might lead to civil penalties recoverable under PAGA, but plaintiff didn’t allege such a claim.