In this episode the WCAB retreats somewhat in new Almaraz/Guzman opinions. The WCAB maintains the same DFEC formula in Ogilvie. Pfizer pays $2.3 billion fine for fraud. Zurich net income drops 53% ss recession takes toll. A study shows low wage earners "pressured" not to make Work Comp claims. Emerging model of "retail" delivery of health care is cost effective. Section 111 reporting requirements for the MMSEA delayed until 2010 or later. WC lawyers and doctors must comply with FTC red flags identity theft rule by November 1. Judge exempts 6,000 SCIF workers from furloughs. Comp premiums decline as layoffs shrink payrolls. Health care reform likely to indirectly affect workers compensation.