Defendants faced with putative wide-reaching class action litigation are equipped with a variety of strategies for defeating class certification. One potential silver bullet, however, expires early, and defendants must deploy it even before a class certification motion is filed in order to wield it effectively. The United States District Court for the Central District of California’s recent decision granting summary judgment to Unilever United States, Inc. in a would-be class action concerning its St. Ives Apricot facial scrub underscores this strategy for (successfully) defeating class certification: Win the case on summary judgment first.