31.  Plaintiff brings this action on behalf of herself and other employees similarly  situated as authorized under the FLSA, 29 U.S.C. § 216(b). The employees similarly  situated are:  Collective Class:  All persons who are or have been employed by IRi as Client  Service Managers including Client Solutions Managers, Client Service Consultants,  Client Service Analysts, and other similar, non-management positions, within the United  States at any time from three years prior to the filing of the initial Complaint through the  final disposition of this case.   32.  Upon information and belief, IRi suffered and permitted Plaintiff and the  Collective Class to work more than 40 hours per week without appropriate overtime  compensation.    33.  IRi’s unlawful conduct has been widespread, repeated, and consistent.    34.  Upon information and belief, IRi knew that Plaintiff and the Collective Class  performed work that required overtime pay. IRi has operated under a scheme to deprive  these employees of appropriate overtime compensation by failing to properly compensate  them for all hours worked.    38.  Plaintiff, on behalf of herself and the California Class, alleges and  incorporates by reference the allegations of the preceding paragraphs.   52.  Plaintiff incorporates by reference in this cause of action each allegation of  the preceding paragraphs as though fully set forth herein.   53.  Plaintiff consents in writing to be party to this action, pursuant to 29 U.S.C.  § 216(b). Plaintiff’s written consent form is attached hereto as Exhibit A. Plaintiff  anticipates that other individuals will sign consent forms and join as plaintiffs.    61.  Plaintiff incorporates by reference in this cause of action each allegation of  the preceding paragraphs as though fully set forth herein.   62.  By failing to pay overtime compensation to Plaintiff and similarly situated  California Class Members as alleged above, IRi has violated California Labor Code § 510  and IWC Wage Orders, which require overtime compensation for non-exempt employees.   63.  IRi’s failure to pay overtime was done willfully, in bad faith, and in knowing  violation of the California Labor Code and IWC Wage Orders.   64.  As a result of IRi’s unlawful acts; Plaintiff and similarly situated California  Class Members have been deprived of overtime compensation in an amount to be  determined at trial, and are entitled to recovery of such amounts, plus interest thereon,  penalties and attorneys’ fees and costs, under California Labor Code § 1194 and California  Code of Civil Procedure § 1021.5, and such other legal and equitable relief as the Court  deems just and proper.  65.  Plaintiff incorporates by reference in this cause of action each allegation of  the preceding paragraphs as though fully set forth herein.   85.  Plaintiff incorporates by reference in this cause of action each allegation of  the preceding paragraphs as though fully set forth herein.   86.  While acting on the direct instruction of IRi and discharging their duties for  it, Plaintiff and California Class Members have incurred work-related expenses. Such  expenses include, but are not limited to, use of home internet for IRi purposes, printing  and photocopying, cloud storage for IRi documents, car expenses for work-related travel,  and expenses incurred while entertaining clients. Plaintiff and California Class Members  incurred these substantial expenses and losses as a direct result of performing their job  duties for IRi.   87.  IRi has failed to properly indemnify Plaintiff and California Class Members  for these expenditures and losses that they incurred in direct consequence of the discharge  of their duties for IRi and/or in obedience of IRi’s direction without properly indemnifying  for these losses, IRi has violated California Labor Code § 2802.   89.  Plaintiff incorporates by reference in this cause of action each allegation of  the preceding paragraphs as though fully set forth herein.    90.  Section 17200 of the California Business & Professions Code – California’s  Unfair Competition Law – prohibits unfair competition by prohibiting, inter alia, any  unlawful or unfair business acts or practices. The foregoing conduct by IRi, as alleged,  constitutes unlawful business actions and practices in violation of § 17200 et seq.    91.  Pursuant to § 17200 et seq., Plaintiff and California Class Members are  entitled to injunctive relief against IRi’s ongoing unlawful business practices. If an  injunction does not issue enjoining IRi from engaging in the unlawful business practices  described above, Plaintiff, California Class Members, and the general public will be  irreparably injured.    92.  Plaintiff and California Class Members have no plain, speedy, and adequate  remedy at law. IRi, if not enjoined by this Court, will continue to engage in the unlawful  business practices described above in violation of § 17200 et seq. in derogation of the  rights of Plaintiff, of California Class Members, and of the general public.   FAILURE TO PROVIDE AND/OR AUTHORIZE MEAL AND REST PERIODS  (Cal. Labor Code §§ 226.7, 512; IWC Wage Orders)  (ON BEHALF OF PLAINTIFF AND THE CALIFORNIA CLASS)   FAILURE TO PROVIDE ACCURATE ITEMIZED WAGE STATEMENTS  (Cal. Labor Code § 226; IWC Wage Orders)  (ON BEHALF OF PLAINTIFF AND THE CALIFORNIA ITEMIZED WAGE  FAILURE TO PAY OVERTIME UNDER CALIFORNIA LAW  (Cal. Labor Code §§ 510, 1194; IWC Wage Orders)  (ON BEHALF OF PLAINTIFF AND THE CALIFORNIA CLASS)   FAILURE TO PAY OVERTIME UNDER THE FLSA  (29 U.S.C. § 207)  (ON BEHALF OF PLAINTIFF AND THE COLLECTIVE CLASS)   FAILURE TO PAY WAGES DUE UPON DISCHARGE  AND WAITING TIME PENALTIES  (Cal. Labor Code §§ 201-204)  FAILURE TO PROVIDE REIMBURSEMENT OF BUSINESS EXPENSES  (Cal. Labor Code § 2802)  ON BEHALF OF PLAINTIFF AND THE CALIFORNIA CLASS   VIOLATIONS OF THE UNFAIR COMPETITION LAW  (Cal. Business & Professions Code § 17200 et seq.)  (ON BEHALF OF PLAINTIFF AND THE CALIFORNIA CLASS)  