10.  Soileau 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 do not 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 Lattimore excluded non-discretionary bonuses  from the regular rate of pay for all hourly employees who worked at the plants, Soileau and all  of the Putative Class Members are similarly situated within the meaning of 29 U.S.C. § 216(b).   12.  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  14.  Soileau incorporates the preceding paragraphs by reference.   15.  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  7.  Soileau and all those similarly situated to him worked for Defendant as hourly  employees. Soileau and all those similarly situated to him regularly worked in excess of 40  hours a week.   9.  Under the FLSA, Lattimore was required to include these non-discretionary  bonuses in calculating the Putative Class Members regular rate of pay for overtime  purposes.   29 U.S.C. §207(e); 29 C.F.R. §778.209.  However, Lattimore improperly excluded  these non-discretionary bonuses from the regular rate of pay, and as a result Plaintiff and the  Putative Class Members were not paid overtime at the proper overtime rate required by federal  law.   Violation of the FLSA  