Wrong. The WARN act does not differentiate between mass firings and mass layoffs of full-time workers. Requirements change once certain firing thresholds are crossed. Firing enough people to cross those thresholds, telling them individually that they are being fired for performance reasons, and not giving advanced notice would be a clear violation. https://www.dol.gov/sites/dolgov/files/ETA/Layoff/pdfs/Worke...
Thanks, I see it now. The document you linked describes three applicable situations for layoffs, but then goes back and says those situations also apply for a bunch of things which are not layoffs.