12.  Defendants employed Plaintiff and class members as group fitness  instructors. Group fitness instructors teach fitness classes to Defendants’ members, such  as spinning, aerobics, and yoga.   13.  Plaintiff worked as a group fitness instructor at Defendants’ Bloomington,  Minnesota location as a group fitness instructor, where she taught yoga classes.   15.  In addition to teaching 60 minutes of class time, Plaintiff’s job as group  fitness instructor required her to perform work that preceded and followed each of her  yoga classes. All group fitness instructors are similarly required to perform pre- and post- class work.   16.  Unpaid post-class time is a matter of course among class members because  Defendants’ Group Fitness Instructor Manual specifically requires unpaid pre-class work  for every class taught:  Every Class, Every Time - You are expected to be in the studio,  ready to teach, 15 minutes before your class with music playing. A  15-minute transition time between classes exists for you to connect  with the members and set the stage and environment for your class.   Exhibit A at 7.   17.  Defendants also required Plaintiff and class members to spend their own  unpaid time compiling current playlists of music for their classes, refusing to compensate  them for the time and downloads required to do so. Indeed, with respect to “Your Music  in Class” and the necessity to compile and pay for such playlists, Defendants’ Manual  instructs that “Your music is your ‘auditory signature’. You are expected to keep it and  change it often,” again, with no regard for the significant time or cost associated with  doing so. Id. at 8.   19.  Taken together, Plaintiff and class members’ unpaid and required pre- and  post-class work included:  a.  Preparing the rooms where classes were held, which preparation  included replacing, arranging, and cleaning any equipment, mats, or  props;  b.  Cleaning rooms after classes, which clean up included wiping down  any equipment, replacing props and mats, and gathering up sweaty  towels and taking them to the laundry, despite the presence of  cleaning personnel on staff; and  c.  Attending and participating in various training and corporate  initiative events and meetings taking place at Defendants’ fitness  centers.    21.  Because Defendants received an uncompensated benefit from the Plaintiff  and class members, Defendants were unjustly enriched in that they failed to pay wages  for the time employees were required to work.   22.  Plaintiff “conferred the benefit of performing unpaid work duties and  structuring the employment relationship in this way could be considered unjust— meaning fraudulent, illegal, or a moral wrongdoing similar in nature to fraud.”  Roth v.  Life Time Fitness, Inc., 16-cv-02476 (JRT/HB), 2017 WL 1628877, at *3 (D. Minn. May  1, 2017).  36.  Under Fed. R. Civ. P. 23(b)(3), Plaintiff defines her proposed, alternate  classes as follows:  Multistate class under Minnesota law  All of Defendants’ group fitness instructors, except for Ohio  group fitness instructors, who performed uncompensated  services for Defendants’ benefit during the maximum period  of time permitted by law.   Minnesota class under Minnesota law  All of Defendants’ group fitness instructors in Minnesota who  performed uncompensated services for Defendants’ benefit  during the maximum period of time permitted by law.    37.  The classes are so numerous and geographically dispersed that joinder of  all members is impracticable. While the exact number of class members is presently  unknown, research conducted by Plaintiff’s counsel indicates that there are over 150 Life  Time Fitness centers, each employing numerous group fitness instructors.    39.  Common questions of law or fact relate to and affect the rights of members  of the alternate classes, including:  a.  Whether Defendants failed to pay class members for time they were  required to work, or attend various operational meetings and  corporate initiative trainings;  b.  Whether class members conferred benefits upon Defendants;  c.  Whether it would be unjust for Defendants to retain the benefits that  class members conferred upon them;  d.  Whether Defendants owe Plaintiff and the class members restitution;  and  e.  Whether Plaintiff and class members are entitled to an award of  reasonable attorney fees, interest, and costs.   40.  Plaintiff’s claims are typical of class members’ claims. Plaintiff is situated  similarly, if not identically, to all class members, as Plaintiff and all class members were  Defendants’ employees and suffered similar types of loss. Plaintiff does not expect that  the amount of unpaid wages claimed by each class member will vary widely. Plaintiff’s  claims are based on the same fundamental factual allegations and legal theories as class  members’ claims.    41.  Plaintiff will adequately represent and protect class members’ interests and  has no interests that conflict with, or are antagonistic to, class members’ interests.   43.  Class certification is the superior procedural vehicle for fairly and  efficiently adjudicating Plaintiff’s claims because:  a.  Common questions of law or fact predominate over any individual  questions that exist within the class and, consequently, efficiencies  to the Court and the parties exist in litigating these common issues  on a classwide basis instead of on a repetitive, individual basis;  b.  Each class member’s damage claim is too small to make individual  litigation an economically viable possibility, and few class members  have any interest in individually controlling the prosecution of  separate actions;  c.  Class treatment is required for optimal deterrence and compensation  and for limiting the Court-awarded, reasonable legal expenses  incurred by class members;  d.  Despite the relatively small size of each class member’s claim, the  aggregate volume of their claims—coupled with the economies of  scale inherent in litigating similar claims on a common basis—will  enable class counsel to litigate this case on a cost-effective basis; and  e.  Plaintiff anticipates no unusual difficulties in this class action’s  management in that all legal and factual questions are common to  the class. 