41.  Plaintiffs bring this action on behalf of themselves and similarly  situated current and former employees of Urban One who elect to opt-in to this  action pursuant to the FLSA, 29 U.S.C. §§ 201 et seq., and specifically, the  collective action provision of 29 U.S.C. § 216(b), to remedy violations of the wage  and hour provisions of the FLSA by Urban One that have deprived Plaintiffs and  others similarly situated of their lawfully earned overtime wages.      43.  In or around August 2012, Ms. Lucas was hired to work as a  production assistant for Radio One Atlanta, a division of Urban One.    44.  In or around July 2012, Ms. Hinton was hired to work as a board  operator and production assistant for Radio One Atlanta, a division of Urban One.    45.  As production assistants and board operators, the primary duties of  Plaintiffs and those similarly situated involved assisting with the production of  radio shows on Urban One radio stations.     46.  This production involved assigning commercials to on-air  personalities, assisting guests on the radio shows, ensuring that commercials play  and that shows come back on time, verifying that commercials and other media  files were properly uploaded and organized on Radio One’s internal systems,  compiling audio files, and other tasks related to the timing of sound production  associated with various Urban One radio shows.    48.  The primary job duties of Plaintiffs and those similarly situated do not  involve the exercise of discretion and independent judgment.    49.   The primary job duties of Plaintiffs and those similarly situated do  not involve administrative support for Urban One’s general business operations.     50.  The primary job duties of Plaintiffs and those similarly situated do not  include managerial responsibilities or the exercise of independent judgment.    51.  Plaintiffs and those similarly situated have no power to hire, fire, or  discipline other employees.    52.  The daily work of Plaintiffs and those similarly situated is and has  always been heavily controlled by their managers, including individuals like  Myron Gigger, as well as by Dave Smith, the former Vice President of Operations  at Radio One Atlanta.    54.  The primary job duties of Plaintiffs and those similarly situated do not  require any special license, certification, or education.   55.  The primary job duties of Plaintiffs and those similarly situated do not  require creative invention or imagination or allow for wide creative license.    56.  While Plaintiffs have both appeared “on-air” on Radio One Atlanta  stations, managers and Smith had ultimate authority and control regarding the  radio stations’ programming and content.  Any “on-air” activity was not a primary  duty of Plaintiffs’ employment.      57.  At all times relevant to this Complaint, Plaintiffs and those similarly  situated have been classified as non-exempt hourly, rather than a salaried,  employees.    58.  Ms. Lucas was hired in August 2012 at a rate of approximately $12.82  per hour and, after more than seven years of employment, continues to make  approximately $12.82 per hour.   59.  Ms. Hinton worked as an unpaid intern with Radio One Atlanta from  in or around 2005 to in or around 2012.    61.  During her time as an employee at Radio One Atlanta, Ms. Hinton  was paid between approximately $10.00 and $12.32 per hour.    62.  In the three years prior to the filing of this action, Plaintiffs and those  similarly situated regularly worked more than forty (40) hours per workweek.    63.  In their history of employment with Urban One, Plaintiffs and those  similarly situated have never been paid at the overtime rate of one and one-half  times their regular rates for hours worked above forty (40) in a given workweek.    64.  Ms. Lucas’ pay stubs reflect that the hours she worked in excess of  forty (40) hours per week were classified as “Regular” hours, such that Plaintiff  Lucas was listed as having worked 100 “Regular” hours in a two-week pay period  and received her normal $12.82 for each of the 100 hours worked.    65.  Plaintiff Hinton’s  pay stubs reflect that the hours she worked in  excess of forty (40) hours per week were classified as “Regular” hours, such that  Plaintiff Hinton was listed as having worked 110 “Regular” hours in a two-week  pay period and received her normal rate, at the time, of $11.50 for each of the 110  hours worked.    67.  The pay stubs for Ms. Hinton also list some hours as “Overtime”  hours; however, Ms. Hinton was paid “half-time” for these hours, such that Ms.  Hinton was paid approximately $6.16 per hour for these “Overtime” hours.    68.  Upon information and belief, Plaintiffs and those similarly situated  worked in excess of forty (40) hours per week but Urban One had a policy of  classifying their overtime hours as “Regular” hours and of paying them “straight  time” rather than the legally mandated overtime rate of one and one-half times  their regular rates or classifying hours as “Overtime” but paying them “half-time”  for those hours.    69.  For all hours worked above forty (40) hours in a workweek, Plaintiffs  and those similarly situated are entitled to overtime wages of one-and-one-half  times their “regular rate of pay,” defined as their total pay for the workweek  divided by the number of hours worked. 29 C.F.R. § 778.118.   70.  Upon information and belief, as part of its regular business practice,  Urban One intentionally, willfully, and repeatedly engaged in a policy, pattern,  and/or practice of violating the FLSA’s overtime provision.    72.  The net effect of Urban One’s unlawful policy and practice is that  Defendant enjoyed ill-gained profits at the expense of Plaintiffs and those similarly  situated.  Individual Disparate Pay Allegations  Desiree Lucas   73.  In or around August 2012, Ms. Lucas was hired at a rate of  approximately $12.82 per hour.    74.  Upon her hire in 2012, Ms. Lucas was told by her supervisor, Smith,  that she would receive a raise within ninety (90) days.     75.  In her seven years at Urban One, Ms. Lucas has never received a  raise.   76.  In or around February of 2018, Ms. Lucas complained to Tim Davies,  the Regional Vice President of Urban One, that she was not receiving adequate  pay.    77.  Mr. Davies then told Ms. Lucas that if she was unhappy with her $12  an hour pay rate, she should “go somewhere else.”    79.  Upon information and belief, similarly situated male employees have  asked Tim Davies for a raise, or for better pay, and have received more favorable  responses than Ms. Lucas.    80.  Upon information and belief, Urban One discriminated against Ms.  Lucas based on her sex by paying similarly situated male employees greater wages  and compensation.   81.  Unlike similarly situated male employees, Ms. Lucas received the  same hourly pay of $12.82 for the past seven years and was never given a pay  increase.   82.  Conversely, upon information and belief, similarly situated male  employees have been provided pay increases in their tenure at Urban One.   Dominique Hinton   83.  In or around September 2005, Ms. Hinton began working as an unpaid  intern at Radio One Atlanta.    84.  In or around July 2012, Ms. Hinton was hired as a paid employee at a  rate of approximately $10.00 per hour.    86.  Upon information and belief, other similarly situated male employees,  including but not limited to John Marshall, made more than $12.32 an hour for the  same work that Ms. Hinton engaged in.    87.  Upon information and belief, Urban One discriminated against Ms.  Hinton based on her sex by paying similarly situated male employees greater  wages and compensation.   88.  Upon information and belief, unlike similarly situated male  employees, Ms. Hinton was given a pay increase of less than $2.50 in  approximately six years of employment with Defendant.    89.  Conversely, upon information and belief, similarly situated male  employees have been provided larger pay increases in their tenure at Urban One.   Individual Title VII Allegations  Dominique Hinton   90.  Ms. Hinton worked as an unpaid intern for Radio One Atlanta from  approximately 2005 to 2012.    91.  In or around July 2012, Ms. Hinton was hired to be a board operator  for Radio One Atlanta.    93.  Smith had the power to hire, fire, and discipline Ms. Hinton.    94.  Smith regularly told Ms. Hinton that her body and her lips “looked  really good,” and that she looked like she would be a good kisser.   95.  On one occasion, Smith called Ms. Hinton into his office, and told her  to turn around.  When Ms. Hinton asked if she had something on her clothes, he  told her, “No, I just wanted to get a good look at that,” referencing her backside.    96.  During weekly air checks with Ms. Hinton, Smith told her, “I think  about you.  Do you think about me?”  Smith also asked her, “What’s your favorite  sex position?”     97.  At these air checks, Smith also asked Ms. Hinton, “Do you like giving  or getting head?” and also told Ms. Hinton, “I think about you when I’m having  sex with my wife.”    98.  Unsure of how to deal with these comments, and unaware of any  sexual harassment policy at Urban One, Ms. Hinton told her direct supervisor,  Mitch Henry, about Smith’s comments and harassment.     Unpaid Overtime Collective Action Allegations   VIOLATION OF THE EQUAL PAY ACT AS TO MS. HINTON  179. Plaintiffs incorporate by reference all preceding paragraphs of this  Complaint.   180. Ms. Hinton was an employee of Urban One, as defined the EPA, 29  U.S.C. § 203(e)(1).   181. Urban One was an “employer” of Ms. Hinton, as defined by 29 U.S.C.  § 203(d).   182. Ms. Hinton is female, and Urban One, in paying Ms. Hinton less than  similarly situated males, has discriminated against Ms. Hinton in violation of the  VIOLATION OF THE EQUAL PAY ACT AS TO MS. LUCAS  167. Plaintiffs incorporate by reference all preceding and subsequent  paragraphs of this Complaint.   168. Ms. Lucas is an employee of Urban One, as defined by the EPA, 29  U.S.C. § 203(e)(1).   169. Urban One is an “employer” of Ms. Lucas, as defined by 29 U.S.C. §  203(d).   170. Ms. Lucas is female, and Urban One, in paying Ms. Lucas less than  similarly situated males, has discriminated against Ms. Lucas in violation of the 