On September 30, 2011, Judge Richard J. Sullivan of the United States District Court for the Southern District of New York issued a decision dismissing in its entirety a lawsuit brought by a senior executive, Martin Levion, seeking $34 million in allegedly unpaid compensation against his former employer, Société Générale, based on claims of breach of contract, breach of the covenant of good faith and fair dealing, unjust enrichment and violations of New York Labor Law. The decision provides useful insight into how courts should apply principles of contract and employment law in cases involving complex incentive compensation structures for high-level and senior employees.