And, belatedly, I see >eight people in eight states who allegedly were students at the school and recruited additional students to enroll ...so not employees

And, belatedly, I see >eight people in eight states who allegedly were students at the school and recruited additional students to enroll ...so not employees as such (presumably the "school" was offering them some financial incentive to do the recruiting work, but if they were students who knew there weren't actual classes etc that makes their intent much clearer.) I grant myself a failing grade for reading comprehension today ¯\_(ツ)_/¯