In ruling on a motion for approval of a settlement of a PAGA claim, the trial court should apply the “fair, adequate and reasonable” standard applied to approval of class action settlements. Because many of the factors used to evaluate class action settlements bear on a settlement’s fairness—including the strength of the plaintiff’s case, the risk, the stage of the proceeding, the complexity and likely duration of further litigation, and the settlement amount—these factors can be useful in evaluating the fairness of a PAGA settlement.  On appeal, the trial court’s order approving the settlement of a PAGA claim is reviewed for abuse of discretion.  While PAGA requires a court to consider comments of the state Labor Workforce and Development Agency regarding the settlement, the court need not follow the agency’s interpretation of applicable statutes.  Also, PAGA does not require a court to consider objections from other employees, including those who filed parallel PAGA actions.  However, the court may consider those objections, if it wishes.  The release in a PAGA settlement may extinguish PAGA claims that were not specifically listed in the PAGA notice where those claims involve the same primary right litigated, since those claims would be barred by res judicata anyway.  A CC 1542 waiver of unknown claims is also appropriate in a PAGA settlement so long as it is confined to claims that were or could have been pleaded in the complaint.  However, the trial court erred in approving a provision of the settlement agreement that allocated a disproportionate percentage of the 25% of statutory penalties recoverable by workers to full-time as opposed to part-time workers without any justification for the different treatment.