In a surprising decision, the Seventh Circuit Court of Appeals held that verbal complaints about wages do not support a retaliation claim under federal law. In Kasten v. Saint-Gobain Performance Plastics Corp., the plaintiff alleged that he had been fired in retaliation for his verbal complaints regarding the location of the time clocks at his employer’s facility. The plaintiff alleged that he verbally complained to his supervisors that the location of the time clocks was illegal because it prevented employees from being paid for time spent donning and doffing their protective gear, and that he had told at least one supervisor that he was thinking of commencing a lawsuit. The plaintiff was subsequently terminated, and he brought a retaliation suit under the Fair Labor Standards Act (FLSA). The district court granted summary judgment to the employer, concluding that plaintiff had not engaged in protected activity because he had not “filed any complaint” about the allegedly illegal location of the time clocks. The Seventh Circuit affirmed, reasoning that purely verbal complaints do not qualify as “protected activity” under the FLSA and therefore cannot be the basis for retaliation suits.