23.10.060, for unpaid wages and overtime wages, on behalf of themselves and a Class of NPSI seafood processing employees who were denied wages and overtime as mandated by the AWHA and governing regulations (“AWHA Class”). This action includes all such employees whom NPSI continues to deprive of required wages and overtime in the future.  41. Plaintiffs seek to bring their FLSA claims on behalf of all persons who worked for NPSI as salmon processing employee from October 19, 2017 until the date of judgment.  42. Those persons whom Plaintiffs seek to represent in the FLSA Collective Action (“FLSA Collective Plaintiffs”) are defined as: Every person who works or has worked as a seafood processing employee in the state of Alaska for North Pacific Seafoods, Inc. during the period from October 19, 2017 to the date of judgment who timely opt in to this action.  45. Plaintiffs bring this class action pursuant to the Federal Rules of Civil Procedure Rule 23(b)(3) and AWHA § 23.10.110(b) to recover damages and penalties under the AWHA §  46. The AWHA Class that Plaintiffs seek to represent is composed of and defined as follows: Every person who works or has worked as a seafood processing employee in the state of Alaska for North Pacific Seafoods, Inc. during the period from October 19, 2018 to the date of judgment who does not timely opt out of this action.  47. Plaintiffs further bring this class action under Alaska Statutes § 23.10.015, for false representations to procure employees, on behalf of themselves and a Subclass of the AWHA Class who came to Alaska or relocated within Alaska based on false or deceptive representations, false advertising, or false pretenses concerning the kind and character of the work to be done, the amount and character of the compensation to be paid for the work, or the sanitary or other conditions of employment (“False Claims Subclass”).  48. The False Claims Subclass that Plaintiffs seek to represent is composed of and defined as follows: Every person who changed location from one place to another in Alaska or was brought into Alaska to work as a seafood processing employee for North Pacific Seafoods, Inc. during the period from October 19, 2018 to the date of judgment who does not timely opt out of this action.  7. The Alaska seafood processing industry provides tens of thousands of jobs each year. Of the approximately 23,000 workers in the industry, 75 percent are from out-of-state. According to Alaska’s Department of Labor and Workforce Development, Bristol Bay, the state’s major salmon processing region, brings in more than 5,000 processing workers from outside Alaska each year.  8. Seasonal workers in Alaska’s seafood industry suffer from wage theft, poor treatment and high numbers of injuries, and high attrition. A May 2020 letter from the state’s Department of Labor and Workforce Development to shore-based fish processing employers identified complaints often found within the fish processing industry, including: “Changes to the rate of pay without the required written notice” “Payment of wages and overtime inconsistent with the Alaska Wage and Hour Act” “Nonpayment of wages for all hours worked” “Employees subjected to unlawful deductions from wages, the withholding of paychecks, or the reimbursement to employers for room and board above statutory limits and without written authorization” “Employees not being provided return transportation when the employer is required to do so.”  Labor Conditions in the Seafood Processing Industry 