On Monday, February 4, the Seventh Circuit decided Espenscheid v. DirectSat, Inc.  The decision is notable for two holdings.  First, Judge Posner held, rather summarily, that there is no good reason to distinguish certification of opt-in FLSA collectives from opt-out Rule 23 classes, and that the same standards should apply.  That is welcome news for defense practitioners, as some courts have suggested, without much justification, that certification under the FLSA may not require as rigorous an analysis.