Defendant contends that even if there was a common illegal policy, the suit cannot proceed as a collective action because Defendant will assert defenses that require individualized analysis for each putative class member (Dkt. #22 at p. 12). Challenges in litigating the suit or a particular need to address each perspective member of the collective action as an individual will be addressed in the second stage. Stier v. Great Plains National Bank, No. 4:15-cv-519, 2016 WL 1572194 at *2 (E.D.Tex. April 19, 2016).

Stier v. Great Plains National Bank, No. 4:15-cv-519, 2016 WL 1572194 (E.D.Tex. April 19, 2016).