Courts have been dancing away from the two-step process for certification of collective actions under the Fair Labor Standards Act (FLSA), and the 6th Circuit is the latest to join the trend. In a recent decision that could have significant impact on the future of FLSA collective actions, the 6th Circuit has borrowed a “strong likelihood” standard from the preliminary injunction context, eliminating the first step of conditional certification which made it easier for FLSA plaintiffs to recruit additional members through notice at a very early stage in litigation. Now FLSA plaintiffs in the 6th Circuit must prove that there is a “strong likelihood” that potential plaintiffs are actually similarly situated to them before the Court will facilitate sending out notice.