12.  Plaintiff Rodgers has been employed by Defendants as a network operations  center (“NOC”) technician since in or around May 2017.   13.  Plaintiff Korff was employed by Defendants as a NOC technician from in or  around February 2018 until in or around February 2019.   14.  NOC technicians receive calls from Defendants’ clients and provide real-time  customer service and technical support for software and hardware troubleshooting to  Defendants’ clients by remotely accessing their computers and servers using high speed internet  connections.   15.  Plaintiffs and other NOC technicians are typically scheduled to work 40 hours  each workweek.   16.  Defendants offer NOC technician service and support to their clients 24 hours a  day, 7 days a week.   17.  In order to provide around-the-clock NOC technician support to their clients,  Defendants require NOC technicians to be engaged to work from home outside of normal  business hours on rotating seven-week schedules. In other words, in addition to their normal  work schedules at Defendants’ facilities, NOC technicians are scheduled to take turns working  seven consecutive days outside of their ordinary schedule.   18.  Plaintiffs and other NOC technicians must have their computer available, be  connected to high speed internet, and prepared to field phone calls and handle customer service  and technical support issues whenever it is their turn to provide NOC technician service and  support outside of normal business hours. In other words, when scheduled to work outside of  4  business hours, NOC technicians perform the same services and tasks as they do during business  hours.   19.  Much if not all of the time spent by Plaintiffs and other NOC technicians when  scheduled to work outside of business hours is in excess of 40 hours in a workweek.   20.  However, Defendants do not pay Plaintiffs and other NOC technicians for all time  worked outside of business hours. Instead, Defendants only pay Plaintiffs and other NOC  technicians for time spent actively handling their clients’ customer service and support needs.   21.  As a result, Defendants have failed to pay Plaintiffs and other NOC technicians  overtime pay at one and one-half times their regular rates of pay for hours worked in excess of  40 in a workweek.   22.  Thus, Defendants’ failure to pay Plaintiffs and other NOC technicians proper  overtime pay for hours over 40 in a workweek is in violation of the FLSA.   23.  Defendants knew and/or acted with reckless disregard of the fact that their failure  to pay Plaintiffs and other NOC technicians overtime violates the overtime requirements of the  24.  Plaintiffs assert their FLSA claims pursuant to 29 U.S.C. § 216(b) as a collective  action on behalf of the following class of similarly situated employees:  All NOC technicians currently or formerly employed by Defendants at any time  since April 2, 2016 who have been required to work outside of business hours at  least once.   25.  Plaintiffs and the class defined above are “similarly situated” as that term is  defined in 29 U.S.C. § 216(b) because, among other things, they were all NOC technicians who  were subject to a common policy and practice that resulted in uncompensated overtime work.  Namely, Defendants have a common policy and practice of requiring them to work outside of  5  business hours without compensation for those hours.  26.  All previous paragraphs are incorporated as though fully set forth herein.   27.  Plaintiffs and the members of the class defined above are employees entitled to  the FLSA’s protections.   28.  Defendants are employers covered by the FLSA.   29.  The FLSA requires that covered employees receive overtime compensation “not  less than one and one-half times” their regular rate of pay.   30.  Defendants have violated the FLSA by failing to compensate Plaintiffs and the  class defined above for all hours above 40 worked in a workweek at one and one-half times their  regular rates of pay.   31.  In violation of the FLSA, Defendants have acted willfully and with reckless  disregard of clearly applicable FLSA provisions. 