Opinion by JUDGE FOX.
¶ 1 This case presents two questions. First, we must decide whether a mandatory, fixed "service charge" for food and drink consumed during a banquet constitutes a "tip" under Colorado Minimum Wage Order Number 35, 7 Code Colo. Regs. 1103-1 (effective Jan. 1, 2019-Dec. 31, 2019), https://perma.cc/GA3G-4ZUP (MWO),
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