11.  Plaintiff Riley and the Collective Rounding Class work, or have  worked, for Kirsan as hourly employees at times since October 5, 2014.   12.  Plaintiff Riley and the Wisconsin Rounding Class work, or have  worked, for Kirsan as hourly employees at Kirsan’s Pleasant Prairie, Wisconsin  location at times since October 5, 2015.   13.  Kirsan specializes in contract manufacturing and precision CNC  machining services at its facility in Pleasant Prairie, Wisconsin.   14.  Since October 5, 2014, Plaintiff Riley, the Collective Rounding Class,  and the Wisconsin Rounding Class have been paid on an hourly basis for their work  at Kirsan’s Pleasant Prairie, Wisconsin facility.   15.  Since October 5, 2015, Kirsan, Plaintiff Riley, and the Wisconsin  Rounding Class have agreed to specific hourly rates which were to be paid to  Plaintiff Riley and the Wisconsin Rounding Class in exchange for their hours  worked under forty in a workweek for Kirsan.    16.  Since October 5, 2014, Kirsan has implemented a time clock rounding  policy applicable to Plaintiff Riley, the Wisconsin Rounding Class, and the  Collective Rounding Class where hourly employees’ starts and end times for their  shifts were rounded in fifteen minute increments.   18.  As an example, under Kirsan’s impermissible time clock rounding  policy, if an employee punched in 3:50 p.m., Kirsan would round up to 4:00 p.m.    19.  Likewise, under Kirsan’s impermissible time clock rounding policy, if  an employee punched out at 3:10 p.m., Kirsan would round down to 3:00 p.m.    20.  Since October 5, 2014, Kirsan has suffered or permitted Plaintiff Riley  to regularly work more than forty hours during workweeks in which Kirsan applied  its time clock rounding policy.   21.  Since October 5, 2014, Kirsan has suffered or permitted the Collective  Rounding Class and the Wisconsin Rounding Class to work more than forty hours  during workweeks in which Kirsan applied its time clock rounding policy.   22.  As a result of applying this time clock rounding policy, Kirsan  improperly denied Plaintiff Riley, the Wisconsin Rounding Class, and the Collective  Rounding Class of compensation at one and one-half times their respective regular  rates for hours worked in excess of forty in many workweeks since October 5, 2014.    23.  Since October 5, 2014, Kirsan’s application of its time clock rounding  policy resulted in employees, including Plaintiff Riley, the Wisconsin Rounding  Class and the Collective Rounding Class, being suffered or permitted to perform  work for Kirsan without compensation at their agreed-upon hourly rates.    25.  On information and belief, Kirsan has not maintained complete and  accurate time records for Plaintiff Riley, the Wisconsin Rounding Class, or the  Collective Rounding Class since October 5, 2014.   26.  Kirsan’s conduct, as set forth in this complaint, was willful and in bad  faith, and has caused significant damages to Plaintiff Riley, the Wisconsin  Rounding Class, and the Collective Rounding Class.  27.  Plaintiff Riley and the Collective Rounding Class are and have been  similarly situated, have and have had substantially similar pay provisions, and are  and have been subject to Kirsan’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 Riley as stated herein are the same as those of the Collective  Rounding Class.   28.  Plaintiff Riley and the Collective Rounding Class seek relief on a  collective basis challenging, among other FLSA violations, Kirsan’s practice of  failing to accurately record all hours worked and failing to pay employees for all  hours worked, including overtime compensation.   30.  Plaintiff Riley brings her Wisconsin state law claims, pursuant to  Wisconsin wage laws, under FED. R. CIV. P. 23 on behalf of the Wisconsin Rounding  Class for violations occurring on or after October 5, 2015 (the “Wisconsin Rounding  Class Period”).   31.  The proposed Wisconsin Rounding Class’ members are so numerous  that joinder of all members is impracticable, and more importantly the disposition  of their claims as a class will benefit the parties and the Court. Although the precise  number of such persons is unknown, and the facts on which the calculation of that  number are presently within the sole control of Kirsan, upon information and belief,  there are over 40 members in the Wisconsin Rounding Class.   33.  Plaintiff Riley is able to fairly and adequately protect the interests of  the Wisconsin Rounding Class, has no interests antagonistic to the Wisconsin  Rounding Class, and has retained counsel experienced in complex wage and hour  class action litigation.   34.  There are questions of fact and law common to the Wisconsin  Rounding Class that predominate over any questions affecting only individual  members. The questions of law and fact common to the class arising from Kirsan’s  actions include, without limitation, the following:  a) Whether Kirsan’s rounding policy violated Wisconsin’s wage laws;  b) Whether Kirsan failed to maintain true and accurate records for all hours  worked by Riley and the Wisconsin Rounding Class as required by  Wisconsin Law;  c) Whether Kirsan failed to pay the Wisconsin Rounding Class for all work  Kirsan suffered or permitted them to perform; and  d) The nature and extent of class-wide injury and the measure of damages  for the injury.   35.  A class action is superior to any other available methods for the fair  and efficient adjudication of the controversy, particularly in the context of wage and  hour litigation where individual plaintiffs lack the financial resources to vigorously  prosecute separate lawsuits in federal court against a corporate defendant,  particularly those plaintiffs with relatively small claims.   37.  Plaintiff Riley, individually and on behalf of the Collective Rounding  Class, reasserts and incorporates by reference all preceding paragraphs as if  restated herein.   38.  Since October 5, 2014, Plaintiff Riley and the Collective Rounding  Class have been entitled to the rights, protections, and benefits provided under the  FLSA, 29 U.S.C. §201 et. seq.   39.  Since October 5, 2014, Kirsan has been and continues to be an  enterprise engaged in commerce within the meaning of 29 U.S.C. §203(s)(1).   40.  Since October 5, 2014, Plaintiff Riley and the members of the  Collective Rounding Class have been employees within the meaning of 29 U.S.C.  § 203(e).   41.  Since October 5, 2014, Kirsan has been an employer of Plaintiff Riley  and the Collective Rounding Class as provided under 29 U.S.C. § 203(d).   42.  Since October 5, 2014, Kirsan has violated the FLSA by failing to pay  overtime compensation due to Plaintiff Riley and the Collective Rounding Class for  each hour worked in excess of forty hours in any given workweek.   44.  Kirsan’s failure to properly compensate Plaintiff Riley and the  Collective Rounding Class and failure to properly record all compensable work time  was willfully perpetrated and Plaintiff Riley and the Collective Rounding Class are  therefore entitled to recover an award of liquidated damages in an amount equal to  the amount of unpaid overtime premium pay described above pursuant to Section  216(b) of the FLSA, 29 U.S.C. § 216(b).    45.  Alternatively, should the Court find that Kirsan did not act willfully in  failing to pay minimum and overtime premium wages, Plaintiff Riley and the  Collective Overtime Class are entitled to an award of pre-judgment interest at the  applicable legal rate.    46.  Pursuant to FLSA, 29 U.S.C. §216(b), successful Plaintiffs are entitled  to reimbursement of the costs and attorneys’ fees expended in successfully  prosecuting an action for unpaid minimum wages and overtime wages.  47.  Plaintiff Riley, individually and on behalf of the Wisconsin Rounding  Class, re-alleges and incorporates by reference all preceding paragraphs as restated  herein.   49.  Since October 5, 2015, Plaintiff Riley and the Wisconsin Rounding  Class were employees within the meaning of Wis. Stat. §§ 103.001 et seq.   50.  Since October 5, 2015, Plaintiff Riley and the Wisconsin Rounding  Class were employees within the meaning of Wis. Stat. §§ 104.01 et seq.   51.  Since October 5, 2015, Plaintiff Riley and the Wisconsin Rounding  Class were employees within the meaning of Wis. Admin. Code §§ DWD 272.001 et  seq.   52.  Since October 5, 2015, Plaintiff Riley and the Wisconsin Rounding  Class were employees within the meaning of Wis. Admin. Code §§ DWD 274.01 et  seq.   53.  Since October 5, 2015, Kirsan was an employer within the meaning of  Wis. Stat. §§ 109.01 et seq.   54.  Since October 5, 2015, Kirsan was an employer within the meaning of  Wis. Stat. §§ 103.001 et seq.   55.  Since October 5, 2015, Kirsan was an employer within the meaning of  Wis. Stat. §§ 104.01 et seq.   56.  Since October 5, 2015, Kirsan was an employer within the meaning of  Wis. Admin. Code §§ DWD 272.001 et seq.   58.  Since October 5, 2015, Kirsan has employed, and/or continues to  employ Plaintiff Riley and the Wisconsin Rounding Class within the meaning of  Wis. Stat. §§ 109.01 et seq.   59.  Since October 5, 2015, Kirsan has employed, and/or continues to  employ Plaintiff Riley and the Wisconsin Rounding Class within the meaning of  Wis. Stat. §§ 103.001 et seq.   60.  Since October 5, 2015, Kirsan has employed, and/or continues to  employ Plaintiff Riley and the Wisconsin Rounding Class within the meaning of  Wis. Stat. §§ 104.01 et seq.   61.  Since October 5, 2015, Kirsan has employed, and/or continues to  employ Plaintiff Riley and the Wisconsin Rounding Class within the meaning of  Wis. Admin. Code §§ DWD 272.001 et seq.   62.  Since October 5, 2015, Kirsan has employed, and/or continues to  employ Plaintiff Riley and the Wisconsin Rounding Class within the meaning of  Wis. Admin. Code §§ DWD 274.01 et seq.   63.  Since October 5, 2015, Plaintiff Riley and the Wisconsin Rounding  Class regularly performed activities that were an integral and indispensable part of  the employees’ principal activities without receiving compensation for these  activities.   65.  Since October 5, 2015, Kirsan had, and continues to have, common  policies, programs, practices, procedures, protocols, routines, and rules of willfully  failing to properly pay the Wisconsin Rounding Class overtime wages for all hours  worked in excess of forty hours in a given workweek.   66.  Wis. Stat. §109.03 requires payment of all wages earned by the  employee to a day not more than 31 days prior to the date of payment.   67.  The foregoing conduct, as alleged above, constitutes continuing, willful  violations of Wisconsin’s law requiring the payment of minimum, overtime, and  agreed upon wages.   68.  As set forth above, Plaintiff Riley and the Rounding Class have  sustained losses in their compensation as a proximate result of Kirsan’s violations.  Accordingly, Plaintiff Riley, individually and on behalf of the Wisconsin Rounding  Class, seeks damages in the amount of their respective unpaid compensation,  injunctive relief requiring Kirsan to cease and desist from its violations of the  Wisconsin laws described herein and to comply with them, and such other legal and  equitable relief as the Court deems just and proper.    70.  Plaintiff Riley, individually and on behalf of the Wisconsin Rounding  Class, seeks recovery of attorneys’ fees and the costs of this action to be paid by  Kirsan, pursuant to the Wisconsin law.  Violation of Wisconsin Law – Unpaid Agreed-Upon Wages and Overtime   Violations of the Fair Labor Standards Act of 1938 as Amended  