(AGAINST ALL DEFENDANTS)  A.  FACTUAL ALLEGATIONS   29.  Defendants operate adult-oriented entertainment facilities located at 1350 SW  2nd Street, Pompano Beach, Florida, 33069.   (Figure 1 – Solid Gold Pompano)   88.  Plaintiff hereby incorporates by reference and re-alleges each and every  allegation set forth in each and every preceding paragraph as though fully set forth herein.   89.  Plaintiff brings this action as an FLSA collective action pursuant to 29 U.S.C.  § 216(b) on behalf of all persons who were or are employed by Defendants as exotic  dancers/entertainers at any time during the three (3) years prior to the commencement of this  action to present.   90.  Plaintiff has actual knowledge that FLSA Class Members have also been denied  overtime pay for hours worked over forty (40) hours per workweek and have been denied pay at  the federally mandated minimum wage rate. That is, Plaintiff worked with other  dancers/entertainers at Solid Gold. As such, she has firsthand personal knowledge of the same  pay violations throughout Defendants’ club. Furthermore, other exotic dancers/entertainers at  Defendants’ club have shared with her similar pay violation experiences as those described in  this Complaint.   UNLAWFUL TAKING OF TIPS IN VIOLATION OF THE FLSA, 29 U.S.C. § 203  (By Plaintiff Individually and on Behalf of the Collective Against All Defendants)  126.  Plaintiff hereby incorporates by reference and re-alleges each and every allegation  set forth in each and every preceding paragraph as though fully set forth herein.  127.  Plaintiff customarily and regularly received more than thirty U.S. Dollars  ($30.00) a month in tips and therefore is a tipped employee as defined in the FLSA, 29 U.S.C. §  203(t), see also 29 C.F.R. § 531.50.   128.  At all relevant times, each Defendants were “employer(s)” or “joint employer(s)”  of Plaintiff within the meaning of the FLSA, 29 U.S.C. § 203(d).  129.  Defendants are engaged in “commerce” and/or in the production of “goods” for  “commerce” as those terms are defined in the FLSA.  130.  Defendants operate an enterprise engaged in commerce within the meaning for  the FLSA, 29 U.S.C. § 203(s)(1), because it has employees engaged in commerce, and because  its annual gross volume of sales made is more than five hundred thousand U.S. Dollars  ($500,000).  131.  Under TIPA:  [a]n employer may not keep tips received by its employees for any  purpose including allowing managers or supervisors to keep any portion of  employees’ tips, regardless of whether or not it takes a tip credit. 