action for all unpaid overtime pay, 100% liquidated damages, and attorneys fees and costs arising out of the Plaintiffs' claims under the Fair Labor Standards Act; Finds that NPS is liable to the Plaintiff and all members of the proposed Rule 23  Upon information and belief Guzman, who was classified and paid by NPS as an hourly employee, would frequently during the past two years receive shift differential pay equal to 15 minutes of straight time pay for each workday, in which she worked in whole or in part on a shift different than her primary shift.  At all of its facilities in Wisconsin, NPS made attendance bonus pay available to each of its hourly employees.  The attendance bonus pay, which was promised to induce the employees to improve their attendance, became mandatory when the employees met the required defined standards to qualify for the bonuses. 1 3 . During at least a portion of the time period that she worked for NPS within the last two years, Guzman received attendance bonus pay from NPS.  Like all machine operators employed by NPS at any of its facilities, at all times during the last two years Guzman was eligible for receiving bonus payments for exceeding the defined hourly standard for her classification and machine. The production bonuses, which were promised by NPS to induce its machine  operators to improve the speed of their work, became mandatory when the machine operators exceeded the defined standard for their classifications and machines. During the past two years, and while working as a machine operator, Guzman  Based on online job advertisements posted by NPS, at NPS' Green Bay Facilities its hourly employees also frequently worked overtime by working, for example, four 12 hour shifts during some workweeks. During workweeks that Guzman received shift differential pay, or earned a  production bonus, or formed a portion ofthe time period for which Guzman received an attendance bonus for her good attendance during the time period, Guzman still received overtime pay equal to no more than 1 .5 times her base hourly wage rate.  2 1 . Plaintiff brings her First Claim for Relief, pursuant to the Fair Labor Standards Act, on her own behalf and on behalf of all other similarly situated NPS hourly employees whose shift differential pay and/or attendance bonuses were not included by NPS when computing their regular rate for overtime pay.  classes for all unpaid straight time and overtime wages that they are owed under Wisconsin law, plus 50% increased damages on all unpaid wages, plus their attorneys fees and costs arising out of the Plaintiffs' claims under Wisconsin law; Grants to the Plaintiff such other and further relief as the Court deems just and  NPS thus applied to Guzman, just like it applied to each of its hourly employees at its Green Bay and Cudahy facilities, its uniform policy of excluding shift differential pay, production bonuses, and attendance bonuses when computing their regular rate for overtime pay. maintained as an "opt-in" collective action pursuant to Section 16(b) of FLSA, 29 U.S.C. §2 16(b), for prospective members of the FLSA Class that are similarly situated to Plaintiff and have claims similar to her first claim for relief.  The claims of the Named Plaintiffs are representative of the claims of members of the FLSA Class in that all members of the class were hourly paid employees of NPS who received shift differential pay, attendance bonuses, and/or production bonuses, and were subject to NPS' uniform policy of computing overtime pay as time and a half the employees' base rate of pay, so that shift differential pay, attendance bonuses, and production bonuses were excluded from the computation of the regular rate used to compute their overtime pay. Plaintiff seeks to represent a class of all employees of NPS who fall within any of the following two subclasses pursuant to Rule 23 of the Federal Rules of Civil Procedure: All hourly paid employees of NPS who, during the time period on or after November 22, 2017 received some shift differential pay or attendance bonus pay from NPS, and could have been scheduled to work more than 40 hours per week; All hourly paid machine operators of NPS who, during the time period on or after November 22, 201 7 received some production bonus pay from NPS and could have been scheduled to work more than 40 hours per week. The persons in the class identified above are so numerous that joinder of all  There are questions of law and fact common to the Wisconsin Unpaid Wage Class (Rule 23 Class) that predominate over any questions solely affecting individual members of the class, including, but not limited to: (a). Whether the Plaintiffs' shift differentials were paid for the perceived inconvenience of working on a different shift, rather than because they performed different kinds of work on different shifts; (b). Whether the attendance and production bonuses were announced in advance to encourage NPS employees to improve their work performance; Whether fact and/or payment of the attendance and production bonuses were guaranteed once the employees met the program eligibility requirements that were announced to the employees long before the payment of the bonuses; (c)- (d). How the employees' overtime pay should be computed after incorporating the attendance, production, and shift differential pay into their regular rates; (e). The employees' eligibility for liquidated damages, attorneys' fees and costs for the underpayments of overtime pay that they have experienced.  Plaintiffs claims are typical of those of the Rule 23 class in that she just like members of both of the proposed subclasses received attendance, production, and shift differential pay from NPS, but always had her overtime pay computed as time and a half her base wage rate, so that the attendance, production, and shift differential pay were never included in computing her overtime pay.  Named Plaintiffwill fairly and adequately protect the interests of the Rule 23 class; and have retained counsel experienced in complex wage and hour litigation. A class action is superior to other available methods for the fair and efficient  paragraphs 1- 30 of the Complaint.  NPS cannot utilize the exemption method outlined in §207(g)(2) of the FLSA to compute the Plaintiffs overtime pay when the Plaintiffs received different pay rates for performing the same work on different shifts, rather than for performing different kinds of work on different shifts.  Shift differential pay paid to the Plaintiff for the inconvenience of working on a less desirable shift constitutes remuneration for employment that must be included in the computation of the Plaintiffs regular rate under §207(e) of the FLSA.  Plaintiff therefore is entitled to receive overtime pay computed using her regular rate, with shift differential pay included in computing her regular rate. Production bonuses and attendance bonuses received by the Plaintiff must be  Alternatively, the production bonuses and attendance bonuses must be included in the regular rate when they were announced to employees by NPS in order to induce the employees to improve their work performance and attendance. NPS therefore violated the FLSA by failing to use the regular rate, computed  including the shift differential pay, production bonuses, and pro-rata portion of attendance bonuses the Plaintiff earned during each workweek, to compute the Plaintiffs overtime pay for each week.  NPS either knew or should have known that its method of computing the Plaintiffs overtime pay violated the FLSA, so that Plaintiff is entitled to recover, in addition to all overtime wages owed to her, an equal amount as liquidated damages; plus the application of a three years statute of limitations.  Plaintiff is entitled to recover from NPS her reasonable attorneys' fees and costs incurred in bringing this count of the Complaint. Count II. Claim for Straight Time and Overtime Pay Under Wisconsin Law. Plaintiff re-allege, and incorporate by reference, the allegations contained in  paragraphs 1- 39 of the Complaint. Because Wisconsin law uses the same concept of the "regular rate" as the FLSA,  Plaintiffs shift differential pay, production bonuses, and attendance bonuses must be included in the regular rate under Wisconsin law for the same reasons why they must be included in the regular rate under the FLSA.  NPS therefore violated Wis. Stat. §109.03(1) and (5) by failing to pay to the Plaintiff, within 3 1 days of when the overtime wages were earned, all overtime pay required to be paid to her pursuant to DWD §274.03.  Pursuant to Wis. Stat. §109.03(5), Plaintiff is entitled to maintain a lawsuit against Froedtert for all straight time and overtime wages that they are entitled to but did not receive pursuant to Wis. Stat. §109.03 and DWD Chapter 274. In such a lawsuit they are also entitled to receive the 50% increased damages authorized by Wis. Stat. § 1 09. 1 1 (2)(a) on all straight time and overtime wages that remain unpaid at the time of the filing of this lawsuit, along with their reasonable attorneys' fees and costs of prosecuting their claims as authorized by Wis. Stat. §109.03(6). WHEREFORE, the Plaintiffs respectfully request the Court to enter an order that: Finds that NPS is liable to the plaintiff and all members of the proposed collective  At all of its facilities in Wisconsin, NPS made shift differential pay available to 