25.  Plaintiffs bring this lawsuit pursuant to 29 U.S.C. § 216(b) as a collective action on  behalf of the following class of potential opt-in litigants:  All individuals who are current or former non-exempt employees of HydroChem,  LLC who performed work in the United States at any time between April 19, 2016  and the present, and who were paid pursuant to a daily rate compensation system  (the “FLSA Class”).   26.  Plaintiff desires to pursue his FLSA claim on behalf of any individuals who opt-in  to this action pursuant to 29 U.S.C. § 216(b).   28.  Specifically, HydroChem paid Plaintiff and the FLSA Class a set amount of pay  per week, regardless of the number of hours worked, and failed to pay overtime compensation as  required by law.   29.  Defendant’s violations have been willful.    30.  There are questions of law and fact common to the class/collective.   31.  The claims or defenses of the representative, Plaintiff Parham, are typical of the  claims or defenses of the class/collective.    32.  The representative, Plaintiff Parham, will fairly and adequately protect the interests  of the collective/class.    33.  The similarly situated employees are uniquely known to HydroChem, are readily  identifiable, and can be located through HydroChem’s records. HydroChem employs many  salaried non-exempt employees throughout the United States. These similarly situated employees  may be readily notified of this action through direct United States mail and/or other means, and  allowed to opt into it pursuant to 29 U.S.C. § 216(b), for the purpose of collectively adjudicating  their claims for overtime compensation, liquidated damages (or, alternatively, interest), and  attorneys’ fees and costs under the FLSA.   34.  Prosecuting this case as a class/collective action for similarly situated employees  who have been unlawfully denied overtime wages will promote judicial efficiency and will best  protect the interest of the class/collective members.   35.  There are no conflicts of interest among the class/collective members.   36.  Plaintiff’s written Consent to this action is attached as Exhibit 1 and incorporated  by this reference.  IV.  38.  The FLSA requires that covered employees be compensated for every hour worked  in the work-week.  See 29 U.S.C. § 206(b).   39.  The FLSA provides that, if an employee is a salaried and non-exempt that they be  compensated for every hour worked in the excess of forty hours (40).   40.  Plaintiff and the other Similarly Situated Employees are entitled to overtime at a  rate of an additional one and one-half times their regular rate of pay for all hours worked in excess  of forty (40) hours per workweek.   41.  Plaintiff and the other Similarly Situated Employees have worked in excess of forty  (40) hours in most workweeks within the past three years.   42.  HydroChem has failed to pay overtime to Plaintiff and the other Similarly  Situated Employees for hours worked in excess of forty (40) hours in the workweeks of the past  three years.   43.  Plaintiff and the other Similarly Situated Employees are further entitled to  recover an additional equal amount as liquidated damages (29 U.S.C. § 216(c)) and attorneys’  fees and costs (29 U.S.C. § 216).   44.  HydroChem’s failure to pay overtime was willful, thus entitling Plaintiff and the  other Similarly Situated Employees to a three-year statute of limitations   45.  During all relevant times, Plaintiff and the other Similarly Situated Employees were  covered employees entitled to the above-described FLSA protections.  V. 