19.  Artech provides staffing services for many industries worldwide, including  information technology and project management.    20.  Haynes worked for Artech from approximately June 2019 until February 2020.   21.  Haynes performed work for Artech’s customer at the Tennessee Valley Authority  Gallatin Fossil Plant in Sumner County, Tennessee.    22.  Haynes was a Start-Up Specialist for Artech.   23.  As a Start-Up Specialist, Haynes assisted the start-up and commissioning of a dry  bottom ash handling system at the Gallatin Fossil Plant.    24.  Haynes reported the hours he works to Artech on a regular basis.    25.  Haynes was not guaranteed a salary.   26.  If Haynes worked fewer than 40 hours in a week, he is only paid for the hours worked.   27.  Haynes regularly worked over 40 hours in a week.    28.  Although he often worked 50 to 60 hours per workweek, Artech never paid Haynes  any overtime but, rather, paid him straight-time-for-overtime.    30.  The hours Haynes and the Straight Time Workers (defined above) work are reflected  in Artech’s records.   31.  Rather than receiving time and half as required by the FLSA, Haynes only received  “straight time” pay for overtime hours worked.     32.  Artech’s “straight time for overtime” payment scheme violates the FLSA.   33.  Artech was and is aware of the overtime requirements of the FLSA.     34.  Artech nonetheless fails to pay certain employees, such as Haynes, overtime.     35.  Artech did not guarantee Haynes and Straight Time Workers a salary.   36.  Artech’s failure to pay overtime to these workers was, and is, a willful violation of the  37.  Artech’s illegal “straight time for overtime” policy extends beyond Haynes.   38.  It is the “straight time for overtime” payment plan that is the “policy that is alleged to  violate the FLSA” in this FLSA collective action. Bursell v. Tommy’s Seafood Steakhouse, No. CIV.A. H- 06-0386, 2006 WL 3227334, at *3 (S.D. Tex. Nov. 3, 2006); Wellman v. Grand Isle Shipyard, Inc., No.  CIV.A. 14-831, 2014 WL 5810529, at *5 (E.D. La. Nov. 7, 2014) (certifying “straight time for  overtime” claim for collective treatment).    40.  Any differences in job duties do not detract from the fact that these workers were  entitled to overtime pay.    41.  The workers impacted by Artech’s “straight time for overtime” scheme should be  notified of this action and given the chance to join pursuant to 29 U.S.C. § 216(b).   