11.  HA provides air travel from North America, Asia, and the South Pacific to  Hawaii. Otico applied for a customer service position with HA around October 2015 and was  interviewed for the position in December 2015.   12.  After completing the interview process, HA informed Otico that she was required  to attend a mandatory training program, which was offered at various locations across the  country. Otico registered for the program held in December 2015 at Oakland Airport.   13.  Before the program started, HA sent Otico a welcome packet.  The packet stated  that the training program was approximately 10 days long, Monday through Saturday, from 8:30  a.m. to 5:00 p.m. It further stated that it was mandatory to attend all training days in their  entirety.  The packet also stated that Trainees were required to review and study course material  outside of class to prepare for quizzes and tests. The packets also stated that the training program  covered, among other things, customer service functions and airport facilities.    25.  Otico re-alleges and incorporates all preceding paragraphs.    26.  Otico and the FLSA Collective were non-exempt employees of HA covered by  the Title 29 U.S.C. § 203(e)(1) of the FLSA, which states that an employee “means any  individual employed by an employer,” and that an employer “includes any person acting directly  or indirectly in the interest of an employer in relation to an employee.”   27.  Under Title 29 U.S.C. § 206, Otico and the FLSA Collective are entitled to  receive at least a minimum wage for all hours worked.  Under Title 29 U.S.C. § 203(g), “hours  worked” includes all hours employees are suffered or permitted to work.   28.  HA required the FLSA Collective to attend training sessions, including Airport  Customer Service Training.  The FLSA Collective was entitled to be compensated for the time  associated with attending training sessions.  HA, however, failed to pay the FLSA Collective at  least minimum wage for all of the time spent in mandatory training sessions, as well as the time  spent studying for the training sessions, in violation of Title 29 U.S.C. § 206.     29.  As a result Otico and the FLSA Collective suffered damages as they were not paid  minimum wages for all hours actually worked.      30.  Otico seeks collective-wide compensation for HA’s unlawful conduct and will  take the appropriate steps to notify and join the FLSA Collective under 29 U.S.C. § 216(b) via  written joinder consents.     32.  Otico re-alleges and incorporates all preceding paragraphs.    33.  Under Title 29 U.S.C. § 207, Otico and the FLSA Collective were entitled to  receive overtime at a rate of 1.5 times their regular rate for any hours worked in excess of 40  hours in a week. During their employment for HA, Otico and the FLSA Collective worked over  40 hours in a week.   34.  HA had a policy and practice of willfully not paying Otico and FLSA Collective  overtime wages for overtime hours worked. HA required Otico and the FLSA Collective to  attend mandatory training sessions and studying for the training sessions.  Performing those tasks  required Otico and the FLSA Collective to work more than 40 hours during the workweek.   35.  As a result, Otico and FLSA Collective suffered damages as they were not paid a  proper overtime rate for all hours they worked in excess of 40 hours per week.   36.  Otico seeks collective-wide compensation for HA’s unlawful conduct and will  take the appropriate steps to notify and join the FLSA Collective under 29 U.S.C. § 216(b) via  written joinder consents.    37.  Under Title 29 U.S.C. §§ 207 and 216(b), Otico and the FLSA Collective is  entitled to recover the full amount of unpaid overtime wages, interest thereon, liquidated  damages, reasonable attorney’s fees and the costs of suit.  38.  Otico re-alleges and incorporates all preceding paragraphs.   Failure To Pay Minimum Wages Under FLSA  (By FLSA Collective Against HA)   Failure To Pay Overtime Wages Under FLSA  (By FLSA Collective Against HA)   Failure to Pay All Hourly Wages Owed  (By California Class Against HA)  