11.  Plaintiff re-alleges and incorporates by reference the above paragraphs as if fully set  forth herein.     12.  RingCentral sells a cloud-based unified telecommunications system and  collaboration solutions.  This system, used in healthcare, financial services, real estate, retail stores,  and enterprises, is a comprehensive cloud phone system.  In addition to telecommunications, the  system includes video and audio conferencing, team messaging and collaboration, and business app  integration features.  RingCentral, who serves thousands of clients around the United States and  throughout the world, regularly receives compensation from its clients for these services that are  delivered across state lines.     13.  Plaintiff Stemple worked for RingCentral as a Business Development  Representative out of Defendant’s office in Denver, Colorado where he cold-called potential buyers  of Defendant’s products.  Defendant provided Plaintiff Stemple with leads, who he called in an  attempt to sell Defendant’s products. RingCentral employs numerous other Inside Sales  Representatives who also sell RingCentral’s products to its clients from inside RingCentral’s offices.   26.  Plaintiff re-alleges and incorporates by reference the above paragraphs as if fully set  forth herein.   27.  Plaintiff brings this action individually and on behalf of all others similarly situated  pursuant to 29 U.S.C. § 216(b).  Plaintiff and the similarly situated individuals work(ed) as Inside  Sales Representatives for Defendant.  The proposed collective is defined as follows:  All persons who worked for Defendant as Business Development  Representatives, Sales Development Representatives, Account Executives, or  other positions with similar job titles and/or duties who were classified as exempt  at any time within three years prior to the commencement of this action (the  “FLSA Collective”).   28.  Plaintiff has consented in writing to be a part of this action pursuant to 29 U.S.C. §  216(b) and his consent form is attached as Exhibit A. As this case proceeds, it is likely that additional  individuals will file consent forms and join as “opt-in” plaintiffs.   42.  Plaintiff, individually and on behalf of the proposed Rule 23 Class, re-alleges and  incorporates by reference the above paragraphs as if fully set forth herein.   43.  Plaintiff brings Count Two individually and as a class action pursuant to Rule 23 of  the Federal Rules of Civil Procedure. The proposed Rule 23 Class is defined as:  All persons who worked for Defendant in Colorado as Business  Development Representatives, Sales Development Representatives,  Account Executives, or other positions with similar job titles and/or duties  who were classified as exempt at any time within three years prior to the  commencement of this action (the “Rule 23 Class”).   51.  Plaintiff, individually and on behalf of the FLSA Collective, re-alleges and  incorporates by reference the above paragraphs as if fully set forth herein.    52.  The FLSA requires covered employers to pay non-exempt employees no less than  one-and-one-half times their regular rate of pay for all hours worked in excess of forty (40) in a  workweek.  29 U.S.C. § 207.   53.  Defendant RingCentral, Inc. is an “enterprise” as defined by the FLSA, 29 U.S.C. §  203(r)(1), and is engaged in commerce within the meaning of the FLSA, § 203(b), (s)(1).    54.  Plaintiff and the FLSA Collective are non-exempt covered employees.  29 U.S.C. §  203(e)(1).    55.  Plaintiff and the FLSA Collective have worked more than forty hours (40) per week  for Defendant during the applicable time period.    56.  Defendant has not properly compensated Plaintiff or the FLSA Collective for their  overtime hours as required by the FLSA.    57.  Defendant failed to make a good-faith effort to comply with the FLSA as it relates  to the compensation of Plaintiff and the FLSA Collective.   58.  Defendant knew Plaintiff and the FLSA Collective worked overtime without proper  compensation, and it willfully failed and refused to pay Plaintiff and the FLSA Collective wages at  the required overtime rates.  See 29 U.S.C. § 255.   59.  Defendant’s willful failure and refusal to pay Plaintiff and the FLSA Collective  overtime wages for time worked violates FLSA. 29 U.S.C. § 207.   63.  Plaintiff individually and on behalf of the proposed Rule 23 Class re-alleges and  incorporates by reference the above paragraphs as if fully set forth herein.   64.  At all relevant times, Plaintiff Stemple and members of the proposed Rule 23 Class  were employees within the meaning of C.R.S. § 84-101(5); 7 C.C.R. § 1103-1:2.   65.  At all relevant times, Defendant was an employer within the meaning of C.R.S. § 8- FAIR LABOR STANDARDS ACT – FAILURE TO PAY OVERTIME  (On Behalf of Plaintiff and the FLSA Collective)   FAILURE TO PAY OVERTIME – COLORADO LAW  C.R.S. § 8-4-101 et seq.; 7 C.C.R. § 1103-1  (On Behalf of Plaintiff and the Proposed Rule 23 Class)  