In Kouba v.Allstate Insurance Co. the U..Court of Appeals for the Ninth Circuit held that using an employee's prior salary to determine pay for employees in a training program was not precluded by the:

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The case specifically addressed the issue of using prior salary as a factor in determining pay for employees in a training program, and whether it violated the Equal Pay Act. The court held that it did not, as long as the employer had a legitimate reason for using prior salary and it was used in a reasonable manner. The other Acts listed in the options are unrelated to the issue at hand.

In Kouba V