10.  Benzon brings this claim under the FLSA as a collective action.   11.  The members of the FLSA Class are similarly situated in all relevant respects. While  their precise job duties might vary somewhat, these differences don’t matter for the purposes of  determining their entitlement to overtime. They are all entitled to overtime after 40 hours in a week  and the overtime they are entitled to must be calculated in a manner consistent with the requirements  of the FLSA. Because NOV excluded non-discretionary bonuses from the regular rate of pay for all  hourly employees who worked in the oilfield, Benzon and all of the Putative Class Members are  similarly situated within the meaning of 29 U.S.C. § 216(b).    12.  Defendant employed a substantial number of hourly employees like Benzon in the  United States during the past 3 years. These workers are geographically disbursed, residing and  working in states across the county. Because these workers do not have fixed work locations, these  individuals may work in different states across the country in the course of a given year.   13.  Absent a collective action, many members of the Putative Class likely will not obtain  redress of their injuries and Defendant will retain the proceeds of its violations of the FLSA.   14.  Furthermore, individual litigation would be unduly burdensome to the judicial  system. Concentrating the litigation in one forum will promote judicial economy and parity among  the claims of individual members of the classes and provide for judicial consistency.  16.  At all relevant times, Defendant has been an employer engaged in interstate  commerce and/or the production of goods for commerce, within the meaning of the FLSA.    17.  Defendant employed Benzon and each member of the Putative Class.   18.  Defendant’s pay policy denied Benzon and the Putative Class Members overtime  compensation at a rate based on all remuneration received as required by the FLSA.   19.  Defendant’s failure to pay Benzon and the Putative Class Members overtime at rates  not less than one and one-half times their proper regular rate violates 29 U.S.C. § 207.   20.  The foregoing conduct constitutes a willful violation of the FLSA. Due to  Defendant’s FLSA violations, Benzon and the Putative Class Members are entitled to recover from  Defendant their unpaid overtime compensation, liquidated damages, reasonable attorney fees, costs,  and expenses of this action.  7.  Benzon and all those similarly situated to him worked for Defendant in the oilfield as  hourly employees. Benzon and all those similarly situated to him regularly worked in excess of 40  hours a week.   8.  Benzon and all those similarly situated to him were eligible to receive and did in fact  receive non-discretionary bonuses.  These non-discretionary bonuses consisted of, but were not  limited to, Rig Pay, Safety Bonuses, Completion Bonuses and Retention Bonuses.   Violation of the FLSA  