12. At all relevant times, Defendants employed Plaintiffs who engaged in interstate commerce or the production of goods for interstate commerce.   13. Defendants qualify as “employers” within the meaning of the FLSA 29 U.S.C. § 203(d).   14. Plaintiffs are “employees” within the meaning of the FLSA 29 U.S.C. § 203(e).  15. Defendant Just Brakes operates hundreds of stores throughout the United States.   17.  Just Brakes operates a Just Brakes service center in Cumberland,  Georgia, located at 2653 Cobb Pkwy., S.E., Atlanta, Georgia 30339 (the  “Cumberland Service Center”).    18.  Just Brakes employed Named Plaintiff at the Cumberland Service  Center.    19.  During his employment at the Cumberland Service Center, Named  Plaintiff worked on goods or materials that have been moved in or produced for  commerce.    20.  For example, Named Plaintiff used Just Brakes’ computer systems,  processed credit card transactions, used tools and sold brake pads.    21.  Just Brakes is an enterprise whose annual gross volume of sales or  business done is at least $500,000.    22.  At all relevant times, Just Brakes has had one or more employees who  handle goods that have traveled in interstate commerce within the meaning of the  33.  Defendant Passaro is the District Manager for the Just Brakes Service  Centers in the Greater Atlanta Area.    34.  Plaintiffs are individuals who are, or have been, employed by  Defendants as technicians in the greater Atlanta area within the last three years  (“Technicians”).     35.  Technicians inspect automobiles, perform diagnostic testing on  automobiles, and repair automobiles, among other things.    36.  Technicians typically work 65-70 hours a week at various Just Brakes  service centers throughout the greater Atlanta area.    37.  As compensation for their hours worked, Defendants pay Technicians  at an hourly rate.    38.  Defendants also pay Technicians non-discretionary bonuses.   39.  The amount of the non-discretionary bonuses Defendants pay to  Technicians is calculated based on a percentage of the sales made by Just Brakes.   40.  Defendants require Technicians to log in at the beginning of each  scheduled shift and to log out at the end of each scheduled shift.    42.  For example, on one occasion, Named Plaintiff had a total of 136 hours  worked in a two-week period.    43.  However, Defendants only paid Named Plaintiff for 79 hours.   44.  Defendants fail to record all hours worked by Technicians.    45.  For example, Defendant Passaro instructed Technicians at the  Cumberland Service Center (including Named Plaintiff) to work off the clock once  they had worked 40 hours in a given week.    46.  Technicians would then be required to work the remainder of the week  off the clock.   47.  Technicians were not paid for hours worked off the clock.    48.  By way of further example, Named Plaintiff typically took a 30-minute  lunch break.    49.  However, Defendant Passaro would charge Named Plaintiff with taking  a one-hour lunch break.    50.  Defendants failed to maintain accurate records of the hours worked by  Technicians, including Named Plaintiff.   52.  Defendants failed to pay Technicians for all hours worked in excess of  40 per week at the required overtime premium rate.   53.  Furthermore, Defendants failed to include non-discretionary bonuses in  the regular rate when determining the applicable overtime premium rate for  Technicians’ hours worked in excess of 40 per week as required by the FLSA.   54.  Defendants paid Technicians an hourly wage and certain non- discretionary bonuses based on a percentage of sales made.    55.  However, Defendants failed to pay Technicians for all hours worked in  excess of 40 per week at 1.5 times the regular rate.    56.  The FLSA’s overtime requirements apply to Defendants.   57.  Technicians are non-exempt employees under the FLSA.    58.  Because Defendants did not pay Technicians for hours worked in  excess of 40 per week at 1.5 times their regular rate, Defendants violated the FLSA.   59.  Defendants’ violation of the FLSA was willful.    60.  Pursuant to the FLSA, Defendants are liable to Plaintiffs for all unpaid  overtime hours, liquidated damages, attorney’s fees and costs.    JOINT EMPLOYERS   THE REQUIRED OVERTIME PREMIUM RATE  