 Plaintiff and those similarly situated worked for a base salary in addition to  commissions based on their sales numbers.     Plaintiff Paul White was paid $50,000.00 per year plus commissions.     Plaintiff and those similarly situated worked over forty (40) hours routinely  and with Defendant’s knowledge and behest throughout their employment with  Defendant.     During the hiring process, Defendant, through its managers, represented to  Plaintiff and those similarly situated that the job was a forty (40) hour per week  position.     Plaintiff and the class of similarly situated employees routinely worked over  forty (40) hours each week with Defendant’s knowledge and behest throughout  their employment with Defendant.     Shortly after his employment began, Plaintiff’s superiors began to pressure,  urge and encourage him and all other inside sales representatives to work beyond  the scheduled 40 hours, including coming in early, staying late and working  through lunches in order to meet goals and quotas and maximize sales.     Defendant, through its managers, encouraged and pressured Plaintiff and  those similarly situated to work as many hours as necessary to meet sales  production numbers.     There was no time tracking methods used by the Defendant to track time  worked by Plaintiff and those similarly situated in the office.     In February 2017, Defendant told its employees that some were entitled to  pay for hours over forty (40), but not others.  Those employees that were paid were  only paid for those hours at an $8 – $9 overtime rate, and Defendant did not pay  overtime on the employee commissions.     During one short period of time, Defendant did instruct employees against  working overtime and even represented that they would pay overtime wages, but  very quickly is was “business as usual”, the majority of sales reps working  overtime hours without being paid and continually warned about hitting numbers  and goals no matter how many hours it took.     Plaintiff, like all other inside sales representatives, was not entirely  concerned over recording or documenting his hours since Defendant made it clear  that they would not and do not pay overtime wages.     Defendant’s managers readily observed Plaintiff and those similarly situated  working overtime within the offices of Defendant.     Plaintiff and all similarly situated inside sales representatives, accessed  electronic and computer systems, telephone, and e-mails, which would, if  produced, help reflect the true hours that they worked.     However, Defendants did not accurately record the hours of these non- exempt employees.     It is unclear whether the Defendant misclassified Plaintiff and all similarly  situated inside sales representatives as Exempt employees, a clearly unlawful and  erroneous position and action, or whether they simply just willfully refused to pay  overtime wages for non-exempt employees and did not throughout the period of  the 3 years preceding the filing of this Complaint properly and accurately record  and track the hours inside sales representatives worked in violation of the FSLA.     Plaintiff and all similarly situated inside sales representatives did not  negotiate or ever agree that their salaries were intended to pay them for all hours,  and had they known that they were non-exempt employees under the FLSA when  hired and entitled to a premium for overtime hours, they never would have agreed  to the compensation plan provide and would have complained and objected to not  being paid overtime wages for all hours worked over 40 in a work week.    Upon information and belief, the class size during the relevant class period is  upwards of 3000 employees nationwide.      Plaintiff, and all other similarly situated inside sales representatives, handle  either inbound or outbound calls to sell telecommunications to businesses.     Inside sales representatives do not supervise two (2) or more full time  employees, and thus cannot meet the Executive Exemption.     The primary job duties of inside sales representatives do not involve the  exercise of independent discretion and judgment in matters of significance, they  are in the production aspect of Defendant’s business, selling its products and  following scripts.  Thus they cannot meet the Administrative Exemption.     Plaintiff and all similarly situated inside sales representatives are micro  managed and highly scrutinized on a daily and weekly basis with very little room if  at all in deviating from strict regulated manners in which to perform their job  duties and responsibilities.    Inside sales representatives do not have decision making authority.     Plaintiff and all inside sales representatives work in a very high pressured,  boiler room type environment.     Plaintiff re-alleges and incorporates by reference all above paragraphs as if  fully set forth herein.     The FLSA requires employers to pay employees wages at a rate no less than  one-and-a-half times their regular hourly rate of pay for all hours worked in excess  of forty (40) hours in individual work weeks. 19 U.S.C. § 207.     Defendant is an “employer” of Plaintiff and those similarly situated within  the meaning of the FLSA.     Defendant is an “enterprise” as defined by the FLSA and engaged in  interstate commerce.     Plaintiff and those similarly situated are not exempt employees under the  FLSA or other Federal rules and regulations.     Defendant has willfully violated the FLSA and is liable for wages for a three  (3) year period of time preceding the filing of this complaint.  Defendant has  known for the past three years that the inside sales representatives were non- exempt employees, and continued refuse to compensate Plaintiff and the class of  similarly situated for overtime hours worked.     Defendant did not make a good faith effort to comply with the FLSA and  owes Plaintiff and those similarly situated liquidated damages and an equal sum of  all wages owed.     Defendant also has failed to pay overtime at the proper rate of one and one  half time the employees’ regular rate of pay including the value of all commissions  and bonuses earned.     Defendant has also violated the record keeping provision of the FLSA, 29  CFR 516.2, which mandates that an Employer record and track the hours of non- exempt employees.     Defendant employs inside sales representatives, upwards of one thousand or  more, working in multiple offices selling telecommunications to businesses  throughout the United States.     Defendant provides telecommunications services, including telephone  services, managed solutions, data products, and network integration, to businesses  throughout the United States.    VIOLATION OF THE FAIR LABOR STANDARDS ACT  