The last few months have seen as many complaints filed by the U.S. Equal Employment Opportunity Commission (EEOC) against wellness programs. On August 20, 2014, the EEOC brought its first direct challenge of a wellness program under Title I of the Americans with Disabilities Act (ADA) against Orion Energy Systems, Inc. (The Orion Suit). On September 30, 2014, the EEOC initiated its second ADA action against Flambeau, Inc.’s wellness program (The Flambeau Suit). The latest petition was filed on October 27, 2014, against Honeywell International, Inc.’s wellness program (The Honeywell Suit), and it includes counts under both the ADA and the Genetic Information Non-Discrimination Act (GINA).