1. The United States Supreme Court’s Genesis holding offered nothing to resolve the circuit split and dodged the central issue: Whether an unaccepted offer of judgment that fully satisfies a plaintiff’s FLSA claim moots the claim.
2. Going forward, the Court’s holding in Genesis is meaningless because it is premised on the contemplation of a situation that should never arise—at least according to the Dissent.
3. To ensure the best chances of proceeding with FLSA claims, lead plaintiffs in collective actions should file motions for collective certification as soon as possible to avoid attempts to moot the case using offers of judgment.