 Plaintiffs bring this action individually, and on behalf of the following  Pennsylvania state-wide class of similarly situated individualc;, pursuant to Rule 23 of the  Federal Rules of Civil Procedure:  All ind1v1duals who were employed by Defendants at "Han Dynasty of  University City Inc." at 371 I Vlarket Street, Philadelphia PA 19104  and "\:ew Han Dynasty lnc ··at 70 Buckwalter Rd, L1rner1ck PA 19468,  Since \1ay I, 2016 (the "Clas<,'')     There are questions of law and fact common to the Class. including, without  limitation:  a. whether Defendants, based on its uniform and company-wide policies and practices,  have failed to pay wages and overtime to Plaintiff~ and the Class pursuant to the P'\t1WA,  b. whether Plamt1ffs and the Class are entitled to overtime compensation for services  rendered in excess of 40 hours per week under the P'\t1W A,  c. whether Defendants acted knowingly, willfully or recklessly in v10lat111g the P'\t1W A,  d whether Plaintiffs and the Class have ">uffered and are entitled to damage">. and. 1f so,  111 what amount,  e. Whether liquidated, punitive damages, or special damages are warranted under the  PMWA, and  f Whether Plamtiffs and the Clac-,s are entitled to declaratory or 1111unct1ve relief under the   Plaintiff Pan was employed as a cook at "\Jew Han Dynasty Inc " located at 70  Buckwalter Rd, Limerick PA 19468 from \'larch 2. 2016 until \'lay 2. 2018. He was primarily  responsible for frying food for the Defendants' re!'itaurant patrons    Throughout that time and, upon information belief. both before that time  (throughout the Class Period) and continuing unti I present, the Defendants have likewise employed  other individuals, like the Plaintiff (the Collective Action \'!embers/the Class) in positions that  required little skill and no capital providing chef. server, deli..,ery and other general restaurant  services.    From March 2, 2016 until May 2, 2018. Plaintiff Pan worked at "'\ew Han Dynasty  Inc." He w,as paid $4,500 per month from '.\'larch 2, 2016 to December 31, 2017 and was paid  $4,700 per month from January I, 2018 to 'v1ay 2. 2018 by cash only     Throughout that time and, upon information belie( both before that time  (throughout the Class Period) and continuing until present, the Defendants have likewise employed  other individuals, like the Plaintiffs (the Collective Action \!!embers/the Class) in positions that  required little skill and no capital providing chef, server, delivery and other general restaurant  services.    During the employment of Plaintiff by Defendants, Plaintiff Zhang was paid $2,700  per month by a combination of cash and check from December, 2015 to October, 2016. From  October, 2016 to October, 2017, Plaintiff Zhang was paid $2,800 per month by a combination of  cash and check. From October, 2017 to ~ovember, 2017, he was paid $2,850 per month by a  combinati<)n of cash and check. From '.\:ovember, 2017 to \!larch. 2018, Plaintiff Zhang was paid  $2,950 pel' month by a combination of cash and check. rrom \!larch, 2018 to present, Plaintiff  Zhang was paid $3,000 by a combination of cash and check.    Plaintiffs re-allege and incorporate by reference, all preceding paragraphs     Defendants are liable to Plaintiffs and similarly situated employees for actual  damages, liquidated damages and equitable relief. pursuant to 29 lJ S.C. § 2 I 6(b), as \\<ell as  reasonable' attorneys' fees. costs and expenses.   Plaintiffs re-allege and incorporate by reference. all preceding paragraphs.    ·y he PMW A requires that covered employees he compensated for every hour  worked in a workweek. See 43 P.S. § 333.104(a).    The P\tlWA requires that employees receive overtime compensation "not less than  one and one-half times" the employee's regular rate of pay for all hours worked over 40 in a  workweek. See 43 P.S. § 333.104(c).    Plaintiffs and the Class are covered employees entitled to the P\tlW A's protections.    Plaintiffs and other members of the Class are not exempt from receiving P\tf WA  overtime b¢nefits.    Defendants are employers required to comply with the P\tl WA's mandates.    Defendants violated the PMWA by failing to pay Plaintiffs and other members of  the Class proper compensation for all hours worked and for time spent working in excess of 40  hours during the workweek.   FAIRLABORSTA~DARDSACT  29 C.S.C. § 201 et seq.  (UNPAID WAGES/OVERTL\1E)   PENNSYLVANIA '.\11~1'.\HJ'.\1 WAGE ACT  43 P.S. §§ 333.10 I et seq.  (lJNPAID WAGES!OVERTI'.\1.E)  