45.  Arc provides weld inspection services to the oilfield and other industries.   46.  Malone began working for Arc in January 2018.   47.  Howard began working for Arc in July 2018.   48.  Kinworthy began working for Arc in September 2018   49.  Malone, Howard, and Kinworthy were employed as inspectors/radiographers  providing inspection services to Arc’s clients.   50.  Malone, Howard, and Kinworthy worked as weld inspectors for Arc.   51.  Malone, Howard, and Kinworthy were hourly employees of Arc.   52.  Arc did not pay Malone, Howard, or Kinworthy a salary.   53.  Arc did not pay Malone, Howard, or Kinworthy on a fee basis.   54.  Arc paid Malone, Howard, and Kinworthy by the hour.   55.  For example, Arc paid Malone $24 per hour.   56.  Arc paid Malone $26 per hour.   57.  And Arc paid Kinworthy $23 per hour.   58.  Malone, Howard, and Kinworthy reported the hours they worked to Arc on a  regular basis.   59.  Malone, Howard, and Kinworthy’s hours are reflected in Arc’s records.   60.  Arc paid Lewis at the same hourly rate for all hours worked, including those in  excess of 40 in a workweek.   62.  When they worked more than 40 hours in a week, Arc did not pay Malone,  Howard, and Kinworthy at 1.5x their regular rate for any of these overtime hours.   63.  Sometimes, Arc would simply pay Malone, Howard, and Kinworthy the same  hourly rate for all hours they worked (“straight time for overtime”).   64.  Even when it paid them overtime, Arc would base that overtime rate only on  their regular hourly rate.   65.  In other words, Arc did not add in non-discretionary bonuses when calculating  Arc’s overtime rate.   66.  But under the FLSA, Arc was required to include those bonuses in calculating  Malone, Howard, and Kinworthy’s overtime pay.   67.  As a result, even when they were paid overtime, Malone, Howard, and  Kinworthy were paid only on their hourly rates, rather than their full “regular rate” as  required by the FLSA.   68.  Arc’s standard operating procedure is to calculate overtime, when paying it at  all, without including the non-discretionary bonuses in its workers’ regular rates of pay.   69.  Arc was well aware of the overtime requirements of the FLSA.   70.  Arc nonetheless failed to pay overtime to certain hourly employees, such as  Malone, Howard, and Kinworthy.   71.  These hourly employees performed work that is primarily manual labor in  nature.   73.  While some training by Arc may be involved, Malone, Howard, Kinworthy,  and the Putative Class Members’ jobs do not require advanced skill or intense study.   74.  Malone, Howard, Kinworthy, and the Putative Class Members are not highly  trained mechanics, technicians, or engineers.   75.  Malone, Howard, Kinworthy, and the Putative Class Members were not  allowed to vary from the job duties that were predetermined for them.   76.  Malone, Howard, Kinworthy, and the Putative Class Members were provided  with mandatory forms, reports, and other documents that had to be completed each day  and/or for each project.   77.  Truly, these workers have little or no discretion in how to do their job, or the  jobs of others they work with.   78.  Even though Malone, Howard, Kinworthy, and the Putative Class Members  perform very routine, technical, and manual labor job duties, Arc uniformly failed to pay  overtime to these workers.   79.  Arc knew, or showed reckless disregard for whether, its policy of not  calculating and paying overtime at the full, regular hourly rate violated the FLSA.   80.  Arc’s failure to pay full overtime to these hourly workers was, and is, a willful  violation of the FLSA.  81.  Malone, Howard, and Kinworthy incorporate all other allegations.   82.  The illegal pay practices Arc imposed on Malone, Howard, and Kinworthy  were likewise imposed on the Putative Class Members.   84.  Numerous individuals were victimized by this pattern, practice, and policy  which is in willful violation of the FLSA.   85.  Based on their experiences and tenure with Arc, Malone, Howard, and  Kinworthy are aware that Arc’s illegal practices were imposed on the Putative Class  Members.   86.  These workers were similarly situated within the meaning of the FLSA.   87.  Arc’s failure to pay overtime compensation at the rates required by the FLSA  result from generally applicable, systematic policies, and practices which are not dependent  on the personal circumstances of the Putative Class Members.  88.  Malone, Howard, and Kinworthy incorporate all other allegations.   89.  By failing to pay Malone, Howard, Kinworthy, and the other Putative Class  Members overtime at 1.5 times their regular rates, Arc violated the FLSA. 29 U.S.C. § 207(a).   90.  Arc owes Malone, Howard, Kinworthy, and the other Putative Class Members  the difference between the rate actually paid and the proper overtime rate.   91.  Because Arc knew, or showed reckless disregard for whether, its pay practices  violated the FLSA, Arc owes these wages for at least the past three years.   92.  Arc also owes Malone, Howard, Kinworthy, and the other Putative Class  Members an amount equal to the unpaid overtime wages as liquidated damages.  