12.  Plaintiff brings this claim for relief for violation of 29 U.S.C. § 2101 et seq., on  behalf of himself and on behalf of all other similarly situated former employees, pursuant to 29  U.S.C. § 2104(a)(5) and Fed. R. Civ P. 23(a), who worked at or reported to Defendant’s Facility  and were terminated without cause on or about October 16, 2015, and within 30 days of that  date, or were terminated without cause as the reasonably foreseeable consequence of the mass  layoffs and/or plant closings ordered by Defendant on or about October 16, 2015, and who are  affected employees, within the meaning of 29 U.S.C. § 2101(a)(5) (the “Class”).     13.  The persons in the Class identified above (“Class Members”) are so numerous  that joinder of all members is impracticable.  Although the precise number of such persons is  unknown, the facts on which the calculation of that number can be based are presently within the  sole control of Defendant.     14.  Upon information and belief, Defendant employed approximately 150 employees  at the Facility and approximately 100 remote employees who reported to and were directed from  the Facility.    15.  On information and belief, the identity of the members of the class and the recent  residence address of each of the Class Members is contained in the books and records of  Defendant.   17.  Common questions of law and fact exist as to each of the Class Members,  including, but not limited to, the following:  (a)  whether the  Class Members were employees of Defendant who worked at  or reported to Defendant’s Facility;  (b)  whether Defendant terminated the employment of the Class Members  without cause on their part and without giving them 60 days advance written notice in violation  of the WARN Act; and   (c)  whether Defendant unlawfully failed to pay the Class Members 60 days  wages and benefits as required by the WARN Act.    18.  Plaintiff’s claims are typical of those of the Class.  Plaintiff, like other Class  Members, worked at or reported to Defendant’s Facility and was terminated without cause on or  about October 16, 2015, due to the mass layoffs and/or plant closings ordered by Defendant.   19.  Plaintiff will fairly and adequately protect the interests of the Class.  Plaintiff has  retained counsel competent and experienced in complex class actions, including the WARN Act  and employment litigation.   21.  Class certification of these claims is appropriate under Fed. R. Civ. P. 23(b)(3)  because questions of law and fact common to the Class predominate over any questions affecting  only individual members of the Class, and because a class action is superior to other available  methods for the fair and efficient adjudication of this litigation – particularly in the context of  WARN Act litigation, where individual plaintiffs may lack the financial resources to vigorously  prosecute a lawsuit in federal court against a corporate defendant, and damages suffered by  individual Class Members are small compared to the expense and burden of individual  prosecution of this litigation.     22.  Concentrating all the potential litigation concerning the WARN Act rights of the  members of the Class in this Court will obviate the need for unduly duplicative litigation that  might result in inconsistent judgments, will conserve the judicial resources and the resources of  the parties and is the most efficient means of resolving the WARN Act rights of all the members  of the Class.    23.  Plaintiff intends to send notice to all Class Members to the extent required by  Rule 23. 