16.  In approximately November 2007, Plaintiff began his employment with  Defendant.   17.  From approximately November 2007 to March 31, 2017, Plaintiff performed  compensable work on behalf of and at the direction of Defendant in the position of Field  Specialist.   18.  During Plaintiff’s employment with Defendant in the position of Field Specialist  from approximately November 2007 to March 31, 2017, Defendant classified Plaintiff and all  other individuals employed in the position of Field Specialist as “salaried, non-exempt” for  compensation purposes – meaning, Defendant compensated Plaintiff and all other Field  Specialists with overtime pay for compensable work performed beyond forty (40) hours each  workweek.   19.  During Plaintiff’s employment with Defendant in the position of Field Specialist  from approximately November 2007 to March 31, 2017, Plaintiff and all other Field Specialists  performed Inspection work.   21.  During Plaintiff’s employment with Defendant in the position of Field Specialist  from approximately November 2007 to March 31, 2017, Plaintiff’s and all other Field  Specialists’ job duties primarily included physically performing non-destructive testing (such as  welding inspections, pump testing inspections, aerial inspections, and ground ladder testing) on  Defendant’s customers’ products.   22.  During Plaintiff’s employment with Defendant in the position of Field Specialist  from approximately November 2007 to March 31, 2017, Plaintiff and all other Field Specialists  physically performed their job duties outside, in weld shops, and/or in factories.   23.  During Plaintiff’s employment with Defendant in the position of Field Specialist  from approximately November 2007 to March 31, 2017, Plaintiff and all other Field Specialists  physically performed their job duties off-site and/or away from Defendant’s place of business.   24.  During Plaintiff’s employment with Defendant in the position of Field Specialist  from approximately November 2007 to March 31, 2017, Plaintiff and all other Field Specialists  did not perform their job duties in an office setting.   25.  During Plaintiff’s employment with Defendant in the position of Field Specialist  from approximately November 2007 to March 31, 2017, Plaintiff’s and all other Field  Specialists’ job duties primarily included performing manual labor.   27.  During Plaintiff’s employment with Defendant in the position of Field Specialist  from approximately November 2007 to March 31, 2017, Plaintiff and all other Field Specialists  regularly travelled for special one-day assignments in other cities or locations during the work  day and/or on weekends.   28.  At times during Plaintiff’s employment with Defendant in the position of Field  Specialist from approximately November 2007 to March 31, 2017, Plaintiff and all other Field  Specialists travelled away from home overnight on work days and/or on weekends.   29.  During Plaintiff’s employment with Defendant in the position of Field Specialist  from approximately November 2007 to March 31, 2017, Plaintiff’s and all other Field  Specialists’ job duties primarily involved the use of skills and technical abilities in gathering  factual information, applying known standards or prescribed procedures, determining which  procedure to follow, and determining whether prescribed standards or criteria were met.   30.  During Plaintiff’s employment with Defendant in the position of Field Specialist  from approximately November 2007 to March 31, 2017, Plaintiff’s and all other Field  Specialists’ job duties primarily involved performing specialized work along standardized lines  involving well-established techniques, procedures, or specific standards that were catalogued or  described in Defendant’s (or others’) manuals or handbooks within closely prescribed limits in  order to determine the correct response to an inquiry or set of circumstances.   32.  During Plaintiff’s employment with Defendant in the position of Field Specialist  from approximately November 2007 to March 31, 2017, Plaintiff and all other Field Specialists  did not compare or evaluate possible courses of conduct and did not act or make decisions  regarding matters of significance after various possibilities have been considered.   33.  During Plaintiff’s employment with Defendant in the position of Field Specialist  from approximately November 2007 to March 31, 2017, Plaintiff and all other Field Specialists  did not have authority to make an independent choice, free from immediate direction or  supervision, or to waive or deviate from Defendant’s established policies and/or procedures  without Defendant’s prior approval.   34.  During Plaintiff’s employment with Defendant in the position of Field Specialist  from approximately November 2007 to March 31, 2017, Plaintiff and all other Field Specialists  did not manage, run, or operate any department or division of Defendant.   35.  During Plaintiff’s employment with Defendant in the position of Field Specialist  from approximately November 2007 to March 31, 2017, no other employees of Defendant  reported directly to Plaintiff or any other Field Specialists.   36.  During Plaintiff’s employment with Defendant in the position of Field Specialist  from approximately November 2007 to March 31, 2017, Plaintiff and all other Field Specialists  did not have the authority or actual ability to hire, fire, demote, promote, and/or establish the  terms and conditions of any other employees’ employment at Defendant.   38.  Effective April 1, 2017, Defendant changed Plaintiff’s and all other Field  Specialists’ compensation classification status from “salaried, non-exempt” to “salaried, exempt”  – meaning, Defendant would no longer compensate Plaintiff and all other Field Specialists with  overtime pay for compensable work performed beyond forty (40) hours each workweek.   39.  Subsequent to April 1, 2017, Defendant changed Plaintiff’s and all other Field  Specialists’ job titles from “Field Specialist” to “Field Engineer.”    40.  Subsequent to April 1, 2017, the job duties of the Field Engineer position did not  change or differ in any way as they existed prior to April 1, 2017: the job duties of the “Field  Engineer” position were exactly the same as the job duties of the “Field Specialist” position.   41.  Prior to April 1, 2017, Plaintiff worked between approximately forty (40) to forty- five (45) hours per workweek.   42.  Subsequent to April 1, 2017, Plaintiff worked between approximately forty-five  (45) to fifty (50) hours per workweek.   43.  Subsequent to April 1, 2017, Plaintiff and all other Field Engineers received only  a bi-weekly salary as compensation for work performed beyond forty (40) hours each workweek.   44.  Subsequent to April 1, 2017, Defendant did not compensate Plaintiff and all other  Field Engineers at an overtime rate of pay for work performed beyond forty (40) hours each  workweek.   46.  Plaintiff and all other Field Engineers electronically record time worked each  workweek via Defendant’s computer and/or software system.   47.  Defendant has access to and records Plaintiff’s and all other Field Engineers’  electronically recorded time worked each workweek via its computer and/or software system.   48.  Despite having a detailed record of time actually worked by Plaintiff and all other  Field Engineers subsequent to April 1, 2017, Defendant did not properly and lawfully  compensate Plaintiff and all other Field Engineers for all hours actually worked, including at an  overtime rate of pay.   49.  Defendant was or should have been aware that Plaintiff and all other Field  Engineers primarily performed non-exempt job duties each workweek during their employment  with it and, subsequent to April 1, 2017, were legally entitled to overtime pay for all hours  worked beyond forty (40) in a workweek.   50.  Defendant’s unlawful pay practices described above resulted in Plaintiff and all  other Field Engineers being deprived of overtime pay for all hours worked beyond forty (40) in a  workweek.   51.  Defendant was or should have been aware that its policies in practice did not  properly and lawfully compensate Plaintiff and all other Field Engineers at an overtime rate of  pay for all hours worked beyond forty (40) in a workweek.   53.  As a result of Defendant’s unlawful policies and practices as described above,  Plaintiff and all other Field Engineers did not receive anywhere from approximately ten (10)  minutes to twenty (20) hours of compensation at an overtime rate of pay for work performed  each workweek.  54.  Plaintiff brings this action on behalf of himself and all other similarly situated  employees as authorized under the FLSA, 29 U.S.C. § 216(b).  The similarly situated employees  include:   FLSA Collective Class:  All persons who are or have  worked at and/or been employed by Defendant in the  position of Field Specialist and/or Field Engineer within  three (3) years prior to this action’s filing date (ECF No. 1)  and who have not been compensated at an overtime rate of  pay for all hours worked in excess of forty (40) hours in a  workweek as a result of Defendant’s “salaried, exempt”  compensation classification.    55.  Plaintiff and the FLSA Collective Class primarily performed non-exempt job  duties each workweek subsequent to April 1, 2017 and, thus, were legally entitled to overtime  pay for all hours worked beyond forty (40) in a workweek.   56.  Defendant, as a matter of policy and practice, did not compensate Plaintiff and the  FLSA Collective Class for all hours of compensable work performed during a workweek.   58.  Defendant suffered or permitted Plaintiff and the FLSA Collective Class to  perform work during the workweek without proper compensation for all hours of work. The  effect of such a practice was for Defendant to deny the FLSA Collective Class their agreed upon  wages, including overtime compensation at one and one-half times the regular rate, for the hours  worked that were not counted as work.   59.  The Claim for Relief is brought under and maintained as an opt-in Collective  Action pursuant to § 216(b) of the FLSA, 29 U.S.C. 216(b), by Plaintiff on behalf of the FLSA  Collective Class.     60.  The FLSA Collective Class claims may be pursued by those who affirmatively  opt in to this case, pursuant to 29 U.S.C. § 216(b).     61.  Upon information and belief, Plaintiff and the FLSA Collective Class are and  have been similarly situated, have and have had substantially similar job requirements and pay  provisions, and are and have been subject to Defendant’s decisions, policies, plans and programs,  practices, procedures, protocols, routines, and rules willfully failing and refusing to compensate  them for each hour worked including overtime compensation. The claims of Plaintiff stated  herein are the same as those of the FLSA Collective Class.   62.  Plaintiff and the FLSA Collective Class seek relief on a collective basis  challenging, among other FLSA violations, Defendant’s practice of failing to properly and  lawfully compensate employees for all hours worked including overtime compensation.   64.  Defendant’s conduct, as set forth in this Complaint, was willful and in bad faith,  and has caused significant damages to Plaintiff and the putative FLSA Collective Class. 