After conducting a market survey, Penton Intergalactic, Ltd., a manufacturer of plows, believes that there is pent-up demand for its product in the expanding agricultural economy of Paraguay. Penton retains Saul Ortiz, a Paraguayan who operates a substantial business selling agricultural implements. Penton’s New York City advertising agency develops the ad campaign and strategy for introduction of the product, including a rather precise time schedule. Sr. Ortiz is to follow Penton’s instructions as the project develops. Sr. Ortiz will use the same employees that he uses in his business operations, except that a few Penton employees will be on-site to assist him. He will receive a commission on each plow sold, plus reimbursement of marketing expenses identifiable as related to the Penton program. Assuming that Paraguayan agency law is consistent with that discussed in this chapter, is Sr. Ortiz a dependent or an independent agent?