20.  BHI provides specialty services and staffing solutions to the power generation, energy,  and government markets. http://www.bhienergy.com/about-us/overview/ (last visited June 4, 2018).   21.  BHI’s workforce includes more than 8,500 experienced project management and  technical, professional, and craft labor operating at over 130 global project locations. Id.    22.  Plaintiffs were hourly employees of BHI.     23.  BHI hired Klapatch around February of 2015 and Lee around January 2017.   24.  Klapatch performed work for BHI in power plants located in Minnesota and  Connecticut.   25.  Lee performed work for BHI in power plants located in Texas.   26.  Klapatch was a Training & Development Coordinator for BHI.   27.  Lee was an Electrical Supervisor for BHI.    28.  BHI paid Lee $75 per approved hour worked.   29.  Klapatch left BHI’s employment in April 2017 and Lee left BHI’s employment in  September 2017.   30.  Plaintiffs reported the hours they worked to BHI on a regular basis.    31.  If Plaintiffs worked fewer than 40 hours in a week, they would be paid only for the  hours worked.   32.  Plaintiffs regularly worked over 40 hours in a week.    33.  The hours Plaintiffs and the Putative Class Members worked are reflected in BHI’s  records.   35.  Rather than receiving time and half as required by the FLSA, Plaintiffs only received  “straight time” pay for overtime hours worked.     36.  BHI’s “straight time for overtime” payment scheme violates the FLSA.   37.  BHI was aware of the overtime requirements of the FLSA.     38.  BHI nonetheless failed to pay certain employees, such as Plaintiffs, overtime.     39.  BHI’s failure to pay overtime to these workers was, and is, a willful violation of the  40.  BHI’s illegal “straight time for overtime” policy extends beyond Plaintiffs.   41.  It is the “straight time for overtime” payment plan that is the “policy that is alleged to  violate the FLSA” in this FLSA collective action. Bursell v. Tommy’s Seafood Steakhouse, No. CIV.A. H- 06-0386, 2006 WL 3227334, at *3 (S.D. Tex. Nov. 3, 2006); Wellman v. Grand Isle Shipyard, Inc., No.  CIV.A. 14-831, 2014 WL 5810529, at *5 (E.D. La. Nov. 7, 2014) (certifying “straight time for  overtime” claim for collective treatment).    42.  BHI paid hundreds of workers using the same unlawful scheme.   43.  Any differences in job duties do not detract from the fact that these workers were  entitled to overtime pay.    44.  The workers impacted by BHI’s “straight time for overtime” scheme should be  notified of this action and given the chance to join pursuant to 29 U.S.C. § 216(b).     45.  Therefore, the class is properly defined as:  All employees of BHI who were, at any point in the past 3 years, paid “straight time  for overtime.” (“FLSA Class”) 