11.  Plaintiff and those he seeks to represent in this action are current and former servers  and bartenders at Defendants’ Local Gastropub restaurants in Memphis, Tennessee.   12.  Defendants pay Plaintiff and other servers and bartenders at their Local Gastropub  restaurants an hourly wage below $7.25. For example, Defendants paid Plaintiff $2.13 per hour.1   13.  In seeking to comply with the FLSA mandate that employees receive a minimum  wage of $7.25 per hour, Defendants purport to utilize a “tip credit” for each hour worked by  Plaintiff and other servers and bartenders at their Local Gastropub restaurants. See 29 U.S.C.  § 203(m). For example, the “tip credit” for Plaintiff was $5.12 for each hour worked.   15.  Such non-tip-producing work includes, but is not limited to, cleaning and  degreasing floor and bar mats, washing glasses and dishes, rolling silverware, sweeping, moping,  cleaning the bathroom, scrubbing baseboard, cleaning light fixtures, stocking drinks, cleaning the  ice machine, cleaning tables, cutting fruit, and stocking condiments and other food supplies.     16.  Defendants also require bartenders to spend significant time each day handling “to  go” orders that are submitted by customers via third-party services, such as Uber Eats and Door  Dash.   17.  Bartenders are required to retrieve “to go” orders that are submitted electronically  by these services, and then submit them manually through Defendants’ customer ordering system.   18.  Then, once Defendants’ kitchen has prepared the food that is ordered “to go”  through third-party services, bartenders prepare the order in a takeout container.   19.  Once the delivery person arrives at Defendants’ restaurant, bartenders are  responsible for providing the order to the delivery person.   20.  Customers are unable to tip the bartenders for this work, and only the delivery  person (who is not employed by Defendant) receives any customer tip associated with these orders.   21.  Defendants require Plaintiff and other servers and bartenders to perform these and  other non-tip-producing work tasks at the beginning of their shifts prior to beginning their tip- producing tasks, throughout their shifts, and at the end of their shifts after finishing their tip- producing tasks.   22.  On a routine basis, customers “walk out” of Defendants’ restaurants without  paying.   24.  As a result, Defendants’ tipped employees are required to share their tips with  Defendants.   25.  Defendants also require Plaintiff and other servers and bartenders to share tips with  non-tipped employees who have no customer interaction. For example, as a bartender, Plaintiff  was required to share tips with barbacks, who are paid more than minimum wage and who do not  interact with customers.  26.  Plaintiff asserts their FLSA claims pursuant to 29 U.S.C. § 216(b) as a collective  action on behalf of the following individuals:  All current and former servers and bartenders employed by  Defendants at their Local Gastropub restaurants at any time since  August 12, 2017.   27.  Plaintiff’s claims should proceed as a collective action because Plaintiff and other  servers and bartenders, having worked pursuant to the common policies described herein, are  “similarly situated” as that term is defined in 29 U.S.C. § 216(b) and the associated decisional law. 