 During Plaintiffs’ employment as Field Service Engineers, Defendant  paid Plaintiffs and other Field Service Engineers on a salary basis and classified  them as exempt under the FLSA.      Defendant has employed, on average, six (6) or so Field Service  Engineers at any given time over the last three (3) years.  Defendant has employed  Field Service Engineers in many states across the country, including in California,  Washington, Oregon, Utah, Delaware, Colorado, Texas, Kansas, Illinois, Georgia,  and Florida.    Defendant subjects all Field Service Engineers, including Plaintiffs, to  the same employment policies and procedures.      Plaintiffs and other Field Service Engineers all reported to the same  Field Engineering Manager.    During Plaintiffs’ employment, Field Service Engineers reported to  Defendant’s Field Engineering Manager, Jireh Providencia (“Providencia”).    Field Service Engineers were expected to work before, during, and  after Defendant’s scheduled business hours (i.e., Monday through Friday 8:00 am  to 5:00pm PT).    Plaintiffs, and those similarly situated, were regularly forced to work  in excess of forty (40) hours per week without overtime compensation.  In addition  to their primary job duties noted above, Field Service Engineers were regularly  required to answer calls and follow any and all instructions from Defendant, make  or respond to customer calls, draft or respond to e-mails, prepare weekly reports,  handle and request parts (or “trunk stock”) as necessary to perform maintenance  and repair services, and travel extensively for service calls throughout the United  States, during and outside of Defendant’s scheduled business hours.    Defendant established a policy and practice of requiring Field Service  Engineers, like Plaintiffs, to work in excess of forty (40) hours per week, without  overtime compensation, in order to maintain a satisfactory level of job  performance with Defendant.    Plaintiffs and other Field Service Engineers were uniformly  misclassified by Defendant as exempt from overtime compensation.    Defendant failed to post or provide notice to its Field Service  Engineers of their federal wage and hour rights under the FLSA. 29 C.F.R. §  516.4.    Defendant has instructed Field Service Engineers to not record their  hours worked.    Defendant uses ADP for payroll processing services.    Defendant’s Field Service Engineers have access to an ADP interface  wherein they can see their payroll information.  This interface also allows Field  Service Engineers to enter information about their hours worked into the ADP  system, which Defendant can see or access.    On at least one occasion, Defendant—through Providencia— explicitly instructed Grey to not enter his hours worked into the ADP system and  to delete any hours worked information he had already put into the ADP system.   Following their conversation, by the time Grey went to check on the hours worked  information that he had previously entered into the ADP system, Providencia had  already deleted from the ADP system the hours worked information that Grey had  entered.    Plaintiffs are representative of those similarly situated Field Service  Engineers employed by Defendant who are current or former employees of  Defendant who were required to work in excess of forty (40) hours per week and  who did not receive overtime compensation.    Plaintiffs, individually and on behalf of those similarly situated Field  Service Engineers, seek relief on a collective basis, challenging, among other  FLSA violations, Defendant’s uniform misclassification of Field Service Engineers  as exempt employees, Defendant’s policy and/or practice of failing to make and  maintain accurate records of their hours worked, and Defendant’s failure to pay  them for all overtime hours worked.      Plaintiffs and other Field Service Engineers have together been the  victim of these common policies or plans of Defendant that violate the FLSA.     Plaintiffs bring this case as an “opt-in” collective action under 29  U.S.C. § 216(b) on behalf of all those who file a Consent to Join form with the  Court.  Plaintiffs’ Consent to Join Forms are attached as Exhibit 1 and Exhibit 2.    Plaintiffs incorporate by reference the above-stated paragraphs as if  set forth fully hereunder.    Plaintiffs and other Field Service Engineers of Defendant are entitled  to the rights, protections and benefits provided under the FLSA.    The FLSA requires employers to pay non-exempt employees one and  one-half times the regular rate of pay at which they are employed for all hours  worked over forty (40) hours per workweek. 29 U.S.C. § 207.    The FLSA also requires employers to make and maintain accurate  records of hours worked each workweek, and to post or provide notice of  employee rights under the FLSA. 29 U.S.C. § 211(c); 29 C.F.R. § 516.4.    Defendant’s actions, policies and/or practices violated the FLSA’s  requirements by failing to compensate Plaintiffs and other Field Service Engineers  for time spent on work activities as described in this Complaint.  Defendant further  violated the FLSA by failing to make and maintain accurate records of hours  worked by Field Service Engineers and to post or provide notice to Field Service  Engineers of their federal wage and hour rights under the FLSA.    Defendant knew or should have known that Plaintiffs and other Field  Service Engineers were non-exempt employees entitled to overtime compensation.   Defendant had knowledge of and information on the job duties and expectations  for Field Service Engineers, their hours worked exceeding forty (40) per  workweek, and their complaint(s) of not being paid overtime compensation for  such hours.    Defendant knowingly and willfully violated the FLSA by failing to  pay overtime compensation to Plaintiffs and other Field Service Engineers, by  failing to make and maintain accurate records of their hours worked, and by failing  to post or provide notice of their federal wage and hours rights under the FLSA.    Defendant has deliberately sought to conceal these violations rather  than remedy them and has refused to fully remedy and correct the issues when  brought to Defendant’s attention for out-of-court resolution.   FAILURE TO PAY OVERTIME IN VIOLATION OF THE FLSA  