16. Defendants provide oil and gas well monitoring services to energy companies nationwide.  17. Defendants employ their workforce to monitor and maintain oil and gas wells in multiple states including Texas, Oklahoma, Colorado, Pennsylvania and North Dakota.  19. Plaintiff and Class Members are employed by Defendants as flow testers. As such, their primary duties consist of monitoring oil and gas wells.  20. Plaintiff and Class Members worked on a regular basis for Defendants at various oil and gas well locations, monitoring such oil and gas wells.  21. Plaintiff Christopher Coker worked for Defendants’ benefit monitoring oil and gas wells at multiple locations throughout Texas.  22. While working for Defendants at these various locations, Plaintiff interacted with and became familiar with the way Defendants treat its other employees with respect to overtime pay and that it misclassifies such workers as independent contractors. Therefore, Plaintiff has first-hand personal knowledge of the same pay violations throughout Defendants’ operation at multiple geographical locations.  23. Defendants paid Plaintiff and Class Members on an hourly basis.  24. Defendants hired/fired, issued pay, supervised, directed, disciplined, scheduled and performed all other duties generally associated with that of an employer with regard to Plaintiff and Class Members.  25. In addition, Defendants instructed Plaintiff and Class Members about when, where, and how they were to perform their work.  27. Furthermore, the degree of investment Plaintiff and Class Members made to perform their work pales in comparison to the expenses Defendants incurred. Plaintiff and Class Members were required to supply simple hand tools, such as wrenches or a hammer. On the other hand, Defendants provided equipment worth hundreds of thousands of dollars including sand separators, water pumps, earth moving equipment, flowback tanks, manifolds, valves, gauges, pipe, test separators, generators, line stacks and flare stacks.  28. A substantial portion of Defendants’ annual revenue is derived from work performed by Plaintiff and Class Members.  29. Despite these facts, Defendants improperly classified Plaintiff and Class Members as independent contractors and not employees.  30. However, at all times, the flow testers and other similarly situated workers were employees of Defendant, as that term is defined under the FLSA and interpretative case law.  31. Defendants tracked the time and days the flow testers worked just as is common for typical employer-employee relationships.  32. Although Plaintiff and Class Members have been required to work more than forty (40) hours per work-week, and did so frequently, they were not compensated at the FLSA mandated time-and-a-half rate for hours in excess of forty (40) per workweek.  34. That is, Defendants paid Plaintiff and Class Members straight time for overtime.  35. No FLSA exemption applies to hourly-paid employees such as Plaintiff and Class Members.  36. Defendants’ method of paying Plaintiff and Class Members in violation of the FLSA was willful and was not based on a good faith and reasonable belief that its conduct complied with the FLSA. Indeed, Defendants’ conduct is all the more egregious because it intentionally set up a paper profile that belied the true interaction and conduct of the company and its workforce. For example, Defendants insisted that its workers submit so-called “invoices,” not time sheets. Defendants even created the “invoice form” its workers were required to use, which was nothing more than a time sheet. Defendants required its workers complete other paper work which Defendants intended to, on the surface, give the impression that their workforce was composed of dozens of independent contractors. In reality, Defendants operated as an oil and gas monitoring company and sold its services through a workforce of dozens of employees.  37. That is, Defendants’ misclassification was not by accident, but a well thought out scheme to reduce its labor costs. Accordingly, Defendants’ violations of the FLSA are willful. 41. Plaintiff has actual knowledge that Class Members have also been denied overtime pay for hours worked over forty (40) hours per workweek as a result of Defendants’ misclassification of its employees.  42. Plaintiff’s knowledge is based on his personal work experience and through communications with other workers of Defendants while performing work throughout Texas.  43. Other hourly paid workers similarly situated to the Plaintiff work for Defendants throughout the United States, but are not paid overtime at the rate of one and one-half their regular rate when those hours exceeded forty (40) hours per workweek.  44. Although Defendants permitted and/or required Class Members to work in excess of forty (40) hours per workweek, Defendants has denied them full compensation for their hours worked over forty (40).  45. Defendants have classified and continue to classify Class Members as independent contractors.  46. Class Members perform or have performed the same or similar work as Plaintiff and were misclassified as independent contractors by Defendants.  47. Class Members are not exempt from receiving overtime pay under the FLSA.  48. As such, Class Members are similar to Plaintiff in terms of relevant job duties, pay structure, their misclassification as independent contractors and/or the denial of overtime pay.  50. The experiences of Plaintiff, with respect to his pay, hours, and duties are typical of the experiences of Class Members.  51. The specific job titles or precise job responsibilities of each Class Member does not prevent collective treatment.  52. All Class Members, irrespective of their particular job requirements, are entitled to overtime compensation for hours worked in excess of forty (40) during a workweek.  53. Although the exact amount of damages may vary among Class Members, the damages for Class Members can be easily calculated by a simple formula. The claims of all Class Members arise from a common nucleus of facts. Liability is based on a systematic course of wrongful conduct by Defendants that caused financial harm to all Class Members.  54. As such, the class of similarly situated Plaintiffs is properly defined as follows: All current and former hourly-paid workers classified as independent contractors who performed work for Defendants associated with monitoring and maintaining oil and gas wells throughout the United States during the three-year period before the filing of this Complaint up to the date the Court authorizes notice.