27.  Plaintiff brings the Second, Third, Fourth, and Fifth Claims for Relief on  behalf of himself and all persons who worked as unpaid YFT Cleaners at CPY in California at any  point(s) in time between May 19, 2012 and the date CPY ceased the YFT program at the relevant  studio(s) (the “California Yoga for Trade Class”).   28.  Excluded from the California Yoga for Trade Class are Defendant,  Defendant’s legal representatives, officers, directors, assigns, and successors, or any individual  who has, or who at any time during the class period has had, a controlling interest in Defendant;  the Judge(s) to whom this case is assigned and any member of the Judges’ immediate family; and  all persons who will submit timely and otherwise proper requests for exclusion from the California  Yoga for Trade Class.   29.  The members of the California Yoga for Trade Class are so numerous that  joinder of all members is impracticable.     30.  Upon information and belief, the size of the California Yoga for Trade Class  is more than 100 individuals.     53.  Plaintiff and the members of the California Yoga for Trade and Studio  Experience Classes and Yoga for Trade Collective defined above (collectively, “Cleaner Class  Members”) have been victims of a common policy and plan perpetrated by Defendant that has  violated their rights under the FLSA and/or the California Labor Code by denying them minimum  wage.   54.  At all times relevant, Defendant’s unlawful conduct, policies, and patterns  or practices described in this Class Action Complaint have been willful.     55.  As part of its ongoing business practice, Defendant has intentionally,  willfully, and repeatedly harmed Plaintiff and the Cleaner Class Members by engaging in a  pattern, practice, and/or policy of violating the FLSA and/or the California Labor Code as  described in this Class Action Complaint.     56.  Defendant has failed to pay minimum wages for all hours worked to  Plaintiff and the Cleaner Class Members.    57.  Defendant failed to keep accurate or adequate records of hours worked by  Plaintiff and the Cleaner Class Members as required by the FLSA and the California Labor Code.   61.  Consistent with its policies and patterns or practices as described herein,  Defendant harmed Plaintiff individually as follows:   62.  Plaintiff worked as a YFT Cleaner for a CPY studio in Berkeley, California  from approximately October 2011 until the end of 2013.  Plaintiff worked shifts of approximately  three hours once a week, cleaning studio facilities, repairing studio equipment, and doing other  assigned projects.     63.  CPY required Plaintiff to work his assigned shifts or to find a replacement  for any shifts he had to miss.     64.  CPY offered Plaintiff a studio membership in exchange for his work as a  YFT Cleaner but did not pay him any wages.   65.  In approximately late 2013 or early 2014, CPY informed Walsh and the  other YFT Cleaners at his studio that it was changing the YFT program.     66.  CPY personnel explained it would begin to pay Cleaners an hourly wage for  their work, but that CPY would require them to purchase the CPY membership they previously  received for free, albeit at a discounted rate, as part of a new SET program.     67.  Plaintiff understood that the purchase of the CPY membership and his  participation in the SET were a “package deal.”    68.  Plaintiff is not aware of any SET employees who did not purchase the CPY  membership.    75.  Plaintiff re-alleges and incorporates by reference all allegations in the  preceding paragraphs.    76.  Defendant has engaged in a widespread pattern, policy, and practice of  violating the FLSA, as detailed in this Class Action Complaint.   77.  The minimum wage provisions set forth in the FLSA, 29 U.S.C. §§ 201 et  seq., and the supporting federal regulations, apply to Defendant and protect Plaintiff and the  members of the Yoga for Trade Collective.     78.  At all relevant times, Defendant has been engaged in commerce and/or in  the production or sale of goods for commerce within the meaning of 29 U.S.C. §§ 203(e), (m), and  206(a), and/or has been engaged in commerce and/or the production or sale of goods for  commerce within the meaning of 29 U.S.C. §§ 203(e), (r), and (s).   85.  Plaintiff re-alleges and incorporates by reference all allegations in the  preceding paragraphs.   86.  Defendant has engaged in a widespread pattern, policy, and practice of  violating the California Labor Code, Cal. Labor Code §§ 1194, 1194.2, 1197, and 1197.1, as  detailed in this Class Action Complaint.   90.  Plaintiff re-alleges and incorporates by reference all allegations in the  preceding paragraphs.   91.  California Labor Code §§ 201 and 202 require Defendant to pay all wages  due within the time specified by law.     92.  California Labor Code § 203 provides that if an employer willfully fails to  timely pay such wages, the employer must continue to pay the wages until the back wages are paid  in full or an action is commenced, up to a maximum of thirty days of wages.   93.  Plaintiff and the members of the California Yoga for Trade and Studio  Experience Classes are entitled to unpaid compensation, but to date have not received such  compensation.   94.  As set forth in this Class Action Complaint, Defendant’s failure to pay  Plaintiff and the members of the California Yoga for Trade and Studio Experience Classes has  been willful and intended to reduce labor costs.   95.  More than thirty days have passed since Plaintiff and certain members of the  California Yoga for Trade and Studio Experience Classes stopped working for CPY.   Cal. Labor Code §§ 1194, 1194.2, 1197, 1197.1 – Minimum Wage  (Brought on behalf of Plaintiff and the California Yoga for Trade and Studio Experience  Classes)   Cal. Labor Code §§ 201, 202, & 203 -- Wage Payment Provisions   (Brought on behalf of Plaintiff and the California Yoga for Trade and Studio Experience  Classes)   Fair Labor Standards Act – Minimum Wage Violation    (Brought on behalf of Plaintiff and the Yoga for Trade Collective)  