16.  Progrexion employs more than 1,500 employees at its call centers in Utah,  Idaho, Arizona, and Oklahoma. Progrexion’s hourly call-center employees receive calls  from Progrexion’s clients and assist those clients with repairing their credit reports.2   17.  Upon information and belief, Progrexion is a privately-held company with  call centers located in Salt Lake City, Utah; North Salt Lake, Utah; West Valley, Utah;  Provo, Utah; Rexburg, Idaho; Idaho Falls, Idaho; Phoenix, Arizona; and Oklahoma City,  Oklahoma.   18.  Plaintiff and the Putative Class Members’ job duties consisted of answering  phone calls made by Progrexion’s clients, answering customer inquiries, troubleshooting  on behalf of customers, and generally assisting customers with matters related to their  credit reports.   19.  Plaintiff Winter was employed by Progrexion in customer service at its call  center located in Phoenix, Arizona from approximately February 2017 until May 2017.   20.  Plaintiff and the Putative Class Members are non-exempt call-center  employees who were (and are) paid by the hour.   22.  In addition to their forty (40) “on-the-clock” hours, Plaintiff and the  Putative Class Members often work up to two and a half hours “off-the-clock” per week  and are not compensated for that time.   23.  Plaintiff and the Putative Class Members have not been compensated for all  the hours they worked for Progrexion as a result of Progrexion’s corporate policy and  practice of requiring all hourly call-center employees to be ready to take their first phone  call the moment their official shift starts.    24.  Specifically, Plaintiff and the Putative Class Members are required to start  and log-in to their computer, open multiple different Progrexion computer programs, log  in to each Progrexion program, and ensure that each Progrexion program is running  correctly—all of which can take up to thirty minutes—before they are able to take their  first phone call, which comes in as soon as their official shift starts.   25.  During this start up time, Plaintiff and the Putative Class Members were not  compensated although they were expected to have completed this process in advance of  their official start time.   27.  As a result, Plaintiff and the Putative Class Members have not been  compensated for all hours worked, including all worked in excess of forty (40) in a  workweek at the rates required by the FLSA.   28.  Progrexion has employed other individuals who perform(ed) the same or  similar job duties under the same pay provisions as Plaintiff.   29.  Progrexion is aware of its obligation to pay for all hours worked and  overtime for all hours worked in excess of forty (40) each week to Plaintiff and the  Putative Class Members but has failed to do so.    30.  Because Progrexion did not pay Plaintiff and the Putative Class Members  time and a half for all hours worked and overtime for all hours worked in excess of forty  (40) each week, Progrexion’s pay policies and practices violated (and continue to violate)  the FLSA.   31.  All previous paragraphs are incorporated as though fully set forth herein.   32.  The FLSA Collective is defined as:  48.  All previous paragraphs are incorporated as though fully set forth herein.   49.  Pursuant to 29 U.S.C. § 216(b), this is a collective action filed on behalf of  all of Progrexion’s employees who have been similarly situated to Plaintiff with regard to  the work they performed and the manner in which they were paid.   50.  Other similarly situated employees of Progrexion have been victimized by  Progrexion’s patterns, practices, and policies, which are in willful violation of the FLSA.   51.  The FLSA Collective Members are defined in Paragraph 32.   53.  Thus, Plaintiff’s experiences are typical of the experiences of the FLSA  Collective Members.   54.  The specific job titles or precise job requirements of the various FLSA  Collective Members do not prevent collective treatment.    55.  All of the FLSA Collective Members—regardless of their specific job  titles, precise job requirements, rates of pay, or job locations—are entitled to be properly  compensated for all hours worked and the proper amount of overtime for all hours  worked over forty (40) hours each week.    56.  Although the issues of damages may be individual in character, there is no  detraction from the common nucleus of liability facts.     57.  Absent a collective action, many members of the proposed FLSA collective  likely will not obtain redress of their injuries and Progrexion will retain the proceeds of  its violations.   58.  Moreover, individual litigation would be unduly burdensome to the judicial  system. Concentrating the litigation in one forum will promote judicial economy and  parity among the claims of the individual members of the classes and provide for judicial  consistency.   A.  FLSA COVERAGE  