This Law Firm Publication by Fisher Phillips discusses three recent decisions in the US District Court of the Eastern District of New York (Francisco v. NY Tex Care, Inc., Wang v. XBB, Inc., and Sevilla v. House of Salads One LLC) in which Federal Judge Pamela Chen dismissed New York Wage Theft Prevention Act (WTPA) claims for lack of subject matter jurisdiction. Potential plaintiffs in New York must now bring WTPA claims in state court on an individual rather than a putative class action basis.