11. ELDOR Process Engineers are not compensated for any work performed  beyond their scheduled 40-hour work week, including any work performed as a result of  off-hours service calls, which can occur at any time during a 24-hour period.   12. Upon information and belief, ELDOR knowingly and in bad faith has  improperly classified Process Engineers as either “professional” or “administrative”  employees who are exempt from the overtime pay requirements of the FLSA. The actual  job duties of the Process Engineers do not support either of these exemptions.   13. As it relates to the improper “professional” exemption, Process Engineers  are not required to have knowledge of an advanced type in a field of science or learning  customarily acquired by a prolonged course of specialized intellectual instructions.  Indeed, in practice, Process Engineers are not required to possess engineering or  equivalent degrees or experience.    14. As it relates to the improper “administrative” exemption, the primary  duties of Process Engineers do not include the performance of “office” work related to  the management or general business operations of the employer, nor do the Process  Engineers exercise discretion and independent judgment with respect to matters of  significance.   15. Specifically, although ELDOR Process Engineers maintain an “engineer”  title, Process Engineers working for ELDOR do not hold engineering degrees, nor do  they perform specific engineering work.   17. Rather, the day-to-day job responsibilities of an ELDOR Process Engineer  are effectively interchangeable with the job responsibilities of an ELDOR “Technician”, a  position ELDOR has classified as non-exempt, and, thus eligible for overtime  compensation.    18. However, ELDOR Technicians are not required to be “on call”.   19. Upon information and belief, ELDOR requires its similarly situated  Process Engineers, who are misclassified as exempt from FLSA overtime pay  requirements, to perform unpaid overtime work in a concerted effort to avoid paying its  employees earned overtime compensation.   20. Of note, the Representative Plaintiff, on two separate occasions, discussed  his concerns about unpaid overtime work and ELDOR’s misclassification of its Process  Engineers to ELDOR’s former Human Resources Director Bridget Farmer and Plant  Manager Fabio Pisconi, but his concerns were never meaningfully addressed by ELDOR.   22. The Representative Plaintiff incorporates by reference herein the  preceding paragraphs of this Complaint.   23. Upon information and belief, ELDOR knowingly and in bad faith has  improperly classified Process Engineers as either “professional” or “administrative”  employees who are exempt from the overtime pay requirements of the FLSA.   24. The actual job duties and qualifications of ELDOR Process Engineers do  not support either of these exemptions.   25. Accordingly, the Representative Plaintiff and Collective Action Members  are not classified properly as exempt employees.   26. At all times relevant to the Complaint, ELDOR was fully aware of the  exemption requirements of the FLSA and knew or should have known that the  Representative Plaintiff and Collective Action Members did not qualify for any  exemption from these requirements.   27. ELDOR willfully and unlawfully ignored the exemption requirements of  the FLSA.   28. ELDOR cannot show that its violations of the FLSA were in good faith and  that it has reasonable grounds for believing that its ongoing acts or omissions were not  violations of the FLSA.     29. As used herein, “willful” is meant in accordance with 29 U.S.C. § 255(a),  and “good faith” and “reasonable grounds” is meant in accordance with 29 U.S.C. § 260.        31. The Representative Plaintiff incorporates by reference herein the  preceding paragraphs of this Complaint.   32. At all times relevant to the Complaint, the Representative Plaintiff and  Collective Action Members were not compensated for any work performed beyond their  scheduled 40-hour work week, including, but not limited to, any work performed as a  result of extra shifts and/or off-hours service calls.   33. The Representative Plaintiff and Collective Action Members regularly  work more than 40 hours per week for ELDOR.     34. The Representative Plaintiff and Collective Action Members were not  exempt from the overtime compensation requirements of the FLSA.   35. Under the FLSA, ELDOR was required to compensate the Representative  Plaintiff and Collective Action Members at the appropriate rate of overtime pay for each  hour over forty (40) they worked in a week for all job-related services provided to  9. At all times relevant to the Complaint, ELDOR violated the FLSA in two  ways:   A) ELDOR knowingly and improperly misclassified the Representative  Plaintiff and Collective Action Members as exempt “professional” or  “administrative” employees pursuant to the FLSA; and  B) The Representative Plaintiff and Collective Action Members were  entitled to overtime wages, but due to their improper misclassification,  ELDOR failed to appropriately compensate the Representative Plaintiff  and Collective Action Members.   Failure to Pay Overtime   Misclassification  