25.  Insight Global is an employment and staffing company operating throughout the  United States and internationally, including in Pennsylvania.   26.  To provide services to their clients, Insight Global employ recruiting personnel,  including Technical Recruiters.   27.  Many of the individuals who worked for Insight Global were paid a salary and  misclassified as exempt employees, and these make up the proposed Putative Classes. While the exact  job titles and job duties may differ, the Putative Class Members are and were subjected to the same or  similar illegal pay practices for similar work.  These so-called exempt employees were paid a salary for  each day worked, regardless of the number of hours that they worked that day (or in that workweek)  without any overtime pay for hours that they worked in excess of forty (40) hours in a workweek.   28.  For example, Prather worked for Insight Global as a Technical Recruiter during the  relevant time period (in Pennsylvania). Throughout his employment with Insight Global, he was  classified as an exempt employee and paid a salary with no overtime compensation.     29.  As a Technical Recruiter, Prather regularly worked more than 40 hours each week  without receiving overtime compensation. On average, Prather estimates he worked approximately 55  hours each week.   31.  The job functions of Prather and the Putative Class Members were primarily technical  in nature, requiring little to no official training, much less a college education or other advanced degree.    32.  Prather and the Putative Class Members perform the same or similar job duties and  are subjected to the same or similar policies and procedures which dictate the day-to-day activities  performed by each person.   33.  Prather and the Putative Class Members also worked similar hours and were denied  overtime as a result of the same illegal pay practice.    34.  The work Prather performed was an essential and integral part of Insight Global’s  core business.   35.  No advanced degree is required to become a recruiter. In fact, Insight Global regularly  hired recruiters who only have a high-school diploma (or less).   36.  Being a recruiter does not require specialized academic training as a standard  prerequisite.    37.  For example, Prather does not have any advanced degree.   38.  Prather and the Putative Class Members did not have any supervisory or management  duties.   39.  To the extent the recruiters make “decisions,” such decisions do not require the  exercise of independent discretion and judgment.   40.  Instead, the recruiters apply well-established techniques and procedures and use  established standards to evaluate any issues.   41.  Recruiters do not set the techniques and procedures utilized to perform their job duties  and do not set quality standards.   43.  With these job duties, the recruiters are clearly non-exempt employees under the  FLSA,  and PMWA.   44.  Insight Global does not pay their recruiters overtime for hours worked in excess of  40 in a single workweek.   45.  Instead, Insight Global pays these workers a base salary for days worked in the office.   46.  Prather and the Recruiters worked for Insight Global in the past three years  throughout the United States, including in Pennsylvania.   47.  As a result of Insight Global’s pay policies, Prather and the Putative Class Members  were denied the overtime pay required by federal and Pennsylvania law, because these workers are, for  all purposes, employees performing non-exempt job duties.   48.  Insight Global keeps accurate records of the hours, or at least the days, its recruiters  work.   49.  Insight Global also keeps accurate records of the amount of pay its recruiters receive.   50.  Because Prather (and Insight Global’s other recruiters) were misclassified as exempt  employees by Insight Global, they should receive overtime for all hours that they worked in excess of  40 hours in each workweek.  V.  62.  Prather incorporates all previous paragraphs and alleges that the illegal pay practices  Insight Global imposed on Prather were likewise imposed on the Putative Class Members.   63.  Numerous individuals were victimized by this pattern, practice, and policy which is in  willful violation of the FLSA and PMWA.    64.  Numerous other individuals who worked with Prather indicated they were improperly  classified as exempt employees, paid in the same manner, performed similar work, and were not  properly compensated for all hours worked as required by state and federal wage laws.   65.  Based on his experiences and tenure with Insight Global, Prather is aware that Insight  Global’s illegal practices were imposed on the Putative Class Members.   66.  The Putative Class Members were all improperly classified as exempt employees and  not afforded the overtime compensation when they worked in excess of forty (40) hours per week.   67.  Insight Global’s failure to pay wages and overtime compensation at the rates required  by state and/or federal law result from generally applicable, systematic policies, and practices which  are not dependent on the personal circumstances of the Putative Class Members.   68.  Prather’s experiences are therefore typical of the experiences of the Putative Class  Members.   69.  The specific job titles or precise job locations of the Putative Class Members do not  prevent class or collective treatment.     70.  Prather has no interest contrary to, or in conflict with, the Putative Class Members.  Like each Putative Class Member, Prather has an interest in obtaining the unpaid overtime wages  owed to them under state and/or federal law.   72.  Absent this action, many Putative Class Members likely will not obtain redress of their  injuries and Insight Global will reap the unjust benefits of violating the FLSA and applicable state  labor laws.   73.  Furthermore, even if some of the Putative Class Members could afford individual  litigation against Insight Global, it would be unduly burdensome to the judicial system.    74.  Concentrating the litigation in one forum will promote judicial economy and parity  among the claims of individual members of the classes and provide for judicial consistency.   76.  Prather’s claims are typical of the claims of the Putative Class Members. Prather and  the Putative Class Members sustained damages arising out of Insight Global’s illegal and uniform  employment policy.    77.  Prather knows of no difficulty that will be encountered in the management of this  litigation that would preclude its ability to go forward as a collective or class action.   78.  Although the issue of damages may be somewhat individual in character, there is no  detraction from the common nucleus of liability facts. Therefore, this issue does not preclude  collective and class action treatment. 