A growing number of employers -- particularly those with seasonal or transient workers -- are using debit cards to pay the help. A 2012 report from the Aite Group estimated that $42.8 billion dollars will be loaded onto these cards this year, double the rate for 2010. The product allows companies to reduce the cost of processing payroll and distributing paper checks, while workers can access their wages outside of bank accounts and check-cashing services. Many of the cards, however, charge a number of fees -- such as the use of non-network ATMs, for example. Fees can eat into the wages of low-pay workers, although some argue that it benefits them if the costs are less than that of traditional bank services. The debit card offered by Walmart gives workers free cash at any Walmart register but applies an extra fee to ATM withdrawals over a monthly limit. Comdata's payroll card has free over-the-counter withdrawals but only one free ATM withdrawal per pay period. In Pennsylvania, McDonald's employee Natalie Gunshannon filed suit over her JPMorgan Chase-branded payroll card, which charged her $1.50 for ATM withdrawals, $5 for over-the-counter cash withdrawals, and $10 for three months of inactivity. The primary issue in the case is whether debit card payment qualifies as "lawful money," since Pennsylvania law requires wages to be paid "in lawful money of the United States or check."