15.  In October, 2012, Ms. Osterholt began taking classes at CorePower’s  studio located at 3232 North Lincoln Ave., Chicago, IL 60657. Through her practice at  CorePower, a CorePower employee recruited her to become an instructor and enroll in  Corepower’s 200-Hour Teacher Training Program.   16.  Ms. Osterholt paid CorePower’s 200-Hour Teacher Training fee on  December 14, 2014 and attended her first associated training class on or around  February 17, 2015. She completed CorePower’s 200-Hour Teacher Training Program  on or around April 19, 2015 and received her general yoga teaching certificate that  same day.   17.  Despite being a certified instructor, to teach at CorePower Ms. Osterholt  was required to complete CorePower’s Extension program at an additional cost of  $500.00. Ms. Osterholt made her $500.00 payment to CorePower in April 2015 and  attended her first CorePower Extensions training class on April 28, 2015. She  completed CorePower’s Extension program on or around May 30, 2015.    18.  After completing CorePower’s 200-Hour Teacher Training Program,  obtaining a teaching certification, and completing additional training through  CorePower’s Extension program, Ms. Osterholt was still required to audition to  become a CorePower intern. Ms. Osterholt’s audition took place on or around June 15,  2015, and she received notice that she had been admitted to CorePower’s internship  program that same day.    19.  Through CorePower’s internship program, Ms. Osterholt was required  to teach 30 classes before becoming a CorePower instructor. Ms. Osterholt taught her  first class as an intern in June 2015 and completed CorePower’s internship program,  teaching her 30th class, on August 9, 2015.    20.  For each of the 30 classes Ms. Osterholt taught as an intern, she was  paid minimum wage for studio instruction time (generally 60 minutes), as well as 30  minutes of front desk time before and after every class. As such, for each of the 30  classes Ms. Osterholt taught as as intern, she was paid minimum wage for 2 hours of  work.    21.  As an intern, Ms. Osterholt was often required to stay at the studio for  more than 2 hours without any additional compensation. Moreover, in addition to the  60 minutes of studio instruction time and 30 minutes of front desk time before and  after every class, Ms. Osterholt spent a significant amount of time preparing for each  class, including developing and practicing sequences, compiling music playlists,  communicating with customers outside the studio, and reading and writing work  related emails. She was not compensated for any of these responsibilities.   22.  After teaching her 30th class as an intern, Ms. Osterholt was finally  considered a CorePower instructor. Ms. Osterholt taught her first yoga class as an  instructor on or around August 10, 2015. She taught her last yoga class as a  CorePower yoga instructor on or around February 4, 2016. Through her employment  as a CorePower instructor, Ms. Osterholt frequently taught classes at CorePower yoga  studios across the Chicagoland area.    23.  For each “class,” Ms. Osterholt was paid $30.00 before taxes.  CorePower’s compensation policy defines “class” as instruction time in the studio  (typically 60 minutes) and 30 minutes of front desk time before and after each class.   24.  Similar to her employment as an intern, as a CorePower instructor, Ms.  Osterholt was often required to stay at the studio for more than 2 hours without any  additional compensation. Moreover, Ms. Osterholt was required to develop and  practice sequences, compile music playlists, communicate with customers outside the  studio, and read and write work related emails. Ms. Osterholt was not compensated  for any of this work.   25.  Preparing to teach classes, as both an intern and instructor, by  developing and practicing sequences, compiling music playlists, communicating with  customers outside the studio, and reading and writing work related emails, was  essential and integral to Ms. Osterholt’s employment with CorePower.   26.  CorePower requires its interns and instructors to prepare for teaching  classes by, among other things, developing and practicing yoga sequences, compiling  music playlists, communicating with customers outside the studio, and reading and  writing work related emails.   27.  CorePower does not compensate its interns and instructors for the time  spent performing these additional tasks which are required as CorePower employees.   28.  CorePower does not compensate its interns and instructors when they  are required to work at the studio for more than the allotted instruction and front desk  time.   29.  CorePower is aware that its interns and instructors, including Ms.  Osterholt, spend significant time on necessary tasks that are separate and distinct  from the time spent teaching classes and attending to their front desk duties, yet  CorePower does not compensate its interns and instructors for performing those tasks.   30.  CorePower is aware that its interns and instructors, including Ms.  Osterholt, are often required to work at their studios for more than the allotted  instruction and front desk time, yet CorePower does not compensate its interns and  instructors for this additional time.   64.  Plaintiff hereby re-alleges and incorporate paragraphs 1 through 49 of  this Complaint as though they were fully set forth herein.   65.  This cause of action is brought by Plaintiff on behalf of a class pursuant  to Federal Rule Civil Procedure Rule 23.   66.  During the Illinois Class Period, CorePower was an “employer” as  defined in the IMWL, and Plaintiff, the Illinois Class, and Illinois Subclass were  “employee(s)” within the meaning of that Act.    67.  The IMWL requires covered employers, such as CorePower, to pay all  non-exempt employees the prevailing minimum wage for all hours worked.   68.  Plaintiff, the Illinois Class, and Illinois Subclass were not exempt from  the requirement that Defendants pay them the prevailing minimum wage for all hours  worked under the IMWL.   69.  During the Illinois Class Period, Defendant did not pay Plaintiff, the  Illinois Class, or Illinois Subclass the prevailing minimum wage for all hours worked  for CorPower; since for certain hours, Plaintiff, the Illinois Class, and Illinois Subclass  were not paid any wages.   70.  Defendant knew, or should have known, that Plaintiff, the Illinois Class,  and Illinois Subclass were performing principal, integral, and essential activities  without being paid for performing those activities.   71.  As a result of CorePower’s failure to pay Plaintiff, the Illinois Class, and  the Illinois Subclass the prevailing minimum wage for all hours worked, CorePower  violated the IMWL.   72.  The foregoing conduct of CorePower constitute violations of the IMWL  which significantly damaged the Plaintiff, the Illinois Class, and the Illinois Subclass.  WHEREFORE, Plaintiff, on behalf of herself, the Illinois Class, and the Illinois  Subclass pray for judgment against Defendant as follows:  A.  Judgment in the amount of all back wages due as provided by the IMWL;  B.  Prejudgment interest on the back wages in accordance with 815 ILCS  205/2 and punitive damages pursuant to the formula set forth in 820  ILCS 105/12(a);   C.  Reasonable attorneys’ fee and costs of this action as provided by the  73.  Plaintiff hereby re-alleges and incorporates paragraphs 1 through 49 of  this Complaint as though they were fully set forth herein.    74.  This cause of action is brought by Plaintiff on behalf of a class pursuant  to Federal Rule Civil Procedure Rule 23.   75.  During the Illinois Class Period, CorePower was an “employer” as  defined in the IWPCA, and Plaintiff, the Illinois Class, and the Illinois Subclass were  “employee(s)” within the meaning of that Act.    76.  CorePower was and is obligated to pay Plaintiff, the Illinois Class, and  Illinois Subclass for all wages earned.   77.  Instead, CorePower instituted practices that resulted in Plaintiff, the  Illinois Class, and the Illinois Subclass working certain time without compensation,  in violation of the IWPCA.   78.  Defendant knew, or should have known, that Plaintiff, the Illinois Class,  and the Illinois Subclass were performing principal, integral, and essential activities  without being paid for performing those activities.    79.  The foregoing conduct of CorePower constitutes violations of the IWPCA  which significantly damaged the Plaintiff, the Illinois Class, and the Illinois Subclass.  WHEREFORE, Plaintiff, on behalf of herself, the Illinois Class, and the Illinois  Subclass pray for judgment against Defendant as follows:  A.  Judgment in the amount of all back wages due as provided by the Illinois  Wage Payment and Collection Act;  B.  Prejudgment interest on the back wages in accordance with 815 ILCS  205/2 and punitive damages pursuant to the formula set forth in 820  ILCS 115/14(a);   C.  Reasonable attorneys’ fee and costs of this action as provided by the  80.  Plaintiff hereby re-alleges and incorporate paragraphs 1 through 31 and  51 though 63 of this Complaint as though they were fully set forth herein.   81.  This Count arises from Defendant’s violations of the Fair Labor  Standards Act, 29 U.S.C. §201, et seq., for its failure to pay minimum wages to Plaintiff  and other similarly situated employees. This claim is brought as a collective action  under the FLSA. Plaintiff’s consent to act in a representative capacity is attached  hereto as Exhibit A.   82.  At all relevant times, CorePower has been and continues to be an  “employer” engaged in interstate “commerce” within the meaning of the FLSA, 29  U.S.C. §203. At all relevant times, CorePower has employed and continues to employ  “employee(s),” including the Plaintiff and each of the FLSA Collective Members.   83.  Defendant CorePower operates, and at all times during the liability  period, has operated studios in numerous states.   84.  Plaintiff consents to sue in this action pursuant to section 16(b) of the  FLSA, 29 U.S.C. §216(b). Additional potential FLSA Collective Members may execute  and file forms consenting to “opt-in” and join as Plaintiffs in this collective action.   85.  Plaintiff and the FLSA Collective Members are not exempt from the  right to receive minimum wages for all hours actually worked.    86.  At all relevant times, CorePower had a policy and practice of failing and  refusing to pay minimum wages for all hours actually worked to its interns and  instructors.   87.  As a result of CorePower’s failure to compensate its interns and  instructors, including Plaintiff and the FLSA Collective Members, with minimum  wages for all hours actually worked, CorePower violated, and continues to violate, the  Violation of the Fair Labor Standard Act – Minimum Wages  (Nationwide FLSA Collective Action)   Violation of the Illinois Minimum Wage law  (Illinois Class Action)   Violation of the Illinois Wage Payment and Collection Act  (Illinois Class Action)  