In Roach v. TL Cannon Corp., No. 13-3070-cv (2d Cir. Feb. 10, 2015), plaintiffs brought a collective action challenging an employer’s practices and moved to certify subclasses. The district court denied certification, finding that the Supreme Court’s Comcast decision required the proponent of the class to offer a damages model that would permit classwide measurement of damages. Reviewing the district court’s decision pursuant to Rule 23(f), the Second Circuit reversed. Prior to Comcast, Second Circuit cases established that a class could be certified even if damages had to be assessed on an individualized basis. Comcast, the Second Circuit ruled, did not overrule these decisions. Instead,Comcast held that where a model for determining classwide damages is used to support certification, it must actually measure damages attributed to the class’s theory of liability. The Second Circuit concluded Comcast did not hold proponents of class certification must advance a classwide damage model. The possibility that damages must be decided on an individual basis may be relevant to whether common issues outweighed individual issues. Still, Comcast did not foreclose certification in a case involving individualized damages.