Would the WARN Act come into play here?

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WARN applies to companies with 100 or more full time employees, so they could potentially be just shy of the number. There are also some exceptions that could apply. I worked at a place that from the layman’s reading you would think had an exception, they were sued in a class action and ended up having to pay some (although a tiny amount to most of us). It seems like the exceptions might be a pretty high standard to meet.

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