| http://www.w3.org/ns/prov#value | - The WHD requires that all six Walling factors be met; otherwise, as the WHD explained in an opinion letter, an intern is an employee even if the internship is academically oriented for the benefit of the students.32 The WHD further advises that an internship involving no or minimal work...is more likely to be viewed as a bona fide educational experience.33 Internships also cannot serve as tria
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