(Class Action Alleging Violations of the Arizona Wage Laws)  A.  VIOLATIONS OF ARIZONA LAW   (Collective Action Alleging FLSA Violations)  A.  FLSA COVERAGE   23.  Web.com provides website development and marketing services to its  clients at its call centers.3   24.  Plaintiffs and the Putative Class Members’ job duties consisted of making  calls to potential clients in order to sell them Web.com’s suite of website services,  including services relating to website creation and maintenance and increasing client  exposure on popular search engines like Google.com and Bing.com.   25.  Plaintiff Howard was employed by Web.com as a Sales Associate in  Scottsdale, Arizona from approximately January 2018 through July 2018.   27.  Plaintiffs and the Putative Class Members are non-exempt call-center  employees who were (and are) paid by the hour, plus commissions received from sales.   28.  Plaintiffs and the Putative Class Members typically worked approximately  forty (40) “on-the-clock” hours per week.   29.  In addition to their forty (40) “on-the-clock” hours, Plaintiffs and the  Putative Class Members often worked more than two (2) hours “off-the-clock” per week  and have not been compensated for that time.   30.  Plaintiffs and the Putative Class Members have not been compensated for  all the hours they worked for Web.com as a result of Web.com’s corporate policy and  practice of requiring its hourly call-center employees to clock-in only when ready to take  their first call.    31.  Specifically, Plaintiffs and the Putative Class Members were required to  start and log in to their computers, open and log in to the Web.com portal, and then open  and log in to the ADP application that Web.com’s employees use to clock in for work— all of which can take up to twenty-five minutes—before they are able to make their first  phone call at the official start of their shift.   32.  During this start up time, Plaintiffs and the Putative Class Members were  not compensated although they were expected to have completed this process in advance  of their official start times.   34.  In addition, Web.com failed to include all commission payments in  Plaintiffs and the Putative Class Members’ regular rates of pay before applying any  overtime multipliers, in violation of 29 C.F.R. § 778.117.   35.  As a result of Web.com’s corporate policies and practices requiring  Plaintiffs and the Putative Class Members to perform their computer start up tasks before  clocking in for work and failing to account for their commission payments in its  calculations of Plaintiffs and the Putative Class Members’ regular rates, Plaintiffs and the  Putative Class Members have not been compensated for all hours worked, including all  worked in excess of forty (40) in a workweek at the rates required by the FLSA.   36.  Web.com has employed other individuals who perform(ed) the same or  similar job duties under the same pay provisions as Plaintiffs.   37.  Web.com is aware of its obligation to pay overtime for all hours worked  and the proper amount of overtime for all hours worked in excess of forty (40) each  week, but has failed to do so.    38.  Because Web.com did not pay Plaintiffs and the Putative Class Members  for all hours worked and did not include all compensation into Plaintiffs and the Putative  Class Member’s regular rate of pay to determine the correct overtime premium to be  applied to all hours worked in excess of forty (40) in a workweek, Web.com’s pay  policies and practices violate the FLSA.    40.  Plaintiffs incorporate by reference all paragraphs and allegations set forth in  the statement of facts of this complaint as though fully and completely set forth herein.   41.  The FLSA Collective is defined as:  57.  All previous paragraphs are incorporated as though fully set forth herein.   58.  Pursuant to 29 U.S.C. § 216(b), this is a collective action filed on behalf of  all of Web.com’s employees who have been similarly situated to Plaintiffs with regard to  the work they performed and the manner in which they have not been paid.   59.  Other similarly situated employees of Web.com have been victimized by  Web.com’s patterns, practices, and policies, which are in willful violation of the FLSA.   60.  The FLSA Collective Members are defined in Paragraph 41.   61.  Web.com’s failure to pay Plaintiffs and the Putative Class Members for all  hours worked and overtime compensation at the rates required by the FLSA, results from  generally applicable policies and practices of Web.com and does not depend on the  personal circumstances of Plaintiffs or the FLSA Collective Members.    62.  Thus, Plaintiff Howard’s experiences are typical of the experiences of the  FLSA Collective Members.   63.  The specific job titles or precise job requirements of the various FLSA  Collective Members do not prevent collective treatment.    64.  All of the FLSA Collective Members—regardless of their specific job  titles, precise job requirements, rates of pay, or job locations— are entitled to be paid for  all hours worked and at the proper overtime rate for all hours worked in excess of forty  (40) hours per workweek.    66.  Absent a collective action, many members of the proposed FLSA collective  likely will not obtain redress of their injuries and Web.com will retain the proceeds of its  rampant violations.   67.  Moreover, individual litigation would be unduly burdensome to the judicial  system. Concentrating the litigation in one forum will promote judicial economy and  parity among the claims of the individual members of the classes and provide for judicial  consistency.   68.  Accordingly, the FLSA collective of similarly situated plaintiffs should be  certified as defined as in Paragraph 41 and notice should be promptly sent.   69.  Plaintiffs incorporates by reference all paragraphs and allegations set forth  in the statement of facts of this complaint as though fully and completely set forth herein.   70.  The Arizona Class is defined as:  70.  VI.  82.  Plaintiff Howard brings his Arizona claims as a class action pursuant to  Rule 23 on behalf of all similarly situated individuals employed by Web.com to work in  Arizona at any time since January 30, 2018.   83.  Class action treatment of Plaintiff Howard and the Arizona Class Members’  claims is appropriate because, as alleged below, all of Rule 23’s class action requisites  are satisfied.   84.  The number of Arizona Class Members is so numerous that joinder of all  class members is impracticable.   86.  Plaintiff Howard and his counsel will fairly and adequately represent the  Arizona Class Members and their interests.   87.  Class certification is appropriate under Federal Rule of Civil Procedure  23(b)(3) because common questions of law and fact predominate over questions affecting  only individual class members and because a class action is superior to other available  methods for the fair and efficient adjudication of this litigation.   88.  Accordingly, the Arizona Class should be certified as defined in Paragraph  