were “denied,” a denial implies a decision on the merits of the claim. Because Judge Bissoon did not reach the merits of the opt-in plaintiffs' claims, for clarity we refer to the claims as dismissed. 14 . Similarly, in the context of class actions, prior to the 1998 amendments to Rule 23(f) that today permit parties to pursue immediate review of certification decisions, decisions de-certifying a class had to await review until the plaintiff obtained a final judgment in the case—even if proceeding as an individual rather than as part of a larger group might mean the "death knell” for the action. Coopers & Lybrand v. Livesay, 437 U.S. 463, 471, 98 S.Ct. 2454, 57 L.Ed.2d 351 (1978). 15 . Compare U.S. Parole Comm’n v. Geraghty, 445 U.S. 388, 400, 100 S.Ct. 1202, 63 L.Ed.2d 479 (1980) (<HOLDING>), with Genesis Healthcare, 133 S.Ct. at 1529
holding that in the rule 23 class action context named plaintiff may appeal a denial of class certification even if his or her individual claims had been satisfied through the entry of judgment holding that tolling applies to a subsequent class action when the prior denial of class certification was based solely on rule 23 deficiencies of the putative representative holding that a rule 23 named plaintiffs acceptance of a settlement offer as to his individual claims mooted his interest in the denial of class certification holding that where the action was filed as a class action and a consent decree was entered into entry of the consent decree was sufficient certification of the action as a class action under rule 23 holding that where named plaintiff was employee of class counsel district court did not abuse its discretion by denying class certification