24. Named Plaintiffs and Class Members were employed by Defendants at call centers in New York and elsewhere in the United States.  25. Throughout their tenures, named Plaintiffs and Class Members worked hours for which they were not paid, including hours worked in excess of forty (40) in a week.  27. Named Plaintiffs and Class Members also performed work after their scheduled shift and after they were logged out of Defendants' phone system or "queue."  28. Named Plaintiffs and Class Members were not compensated by Defendants for all the hours they were suffered or permitted to work because Defendants only paid employees for the time they were logged into Defendants' phone system.  29. Defendants knew Named Plaintiffs and Class Members were not being paid based on the actual hours they were suffered or permitted to work because they tracked the arrival and departure of Named Plaintiffs and Class Members' using identification swipe cards.  30. The net effect of Defendants' pay policy and practice was to willfully deprive Named Plaintiffs and the Class Members of their regular rate of pay for all hours worked. as well as overtime pay for all hours worked in excess of forty (40).  31. in addition, Defendants paid Named Plaintiffs and Class Members non- discretionary bonusesicommissions. Defendants failed to account for these bonusicommissions in calculating Named Plaintitls and Class Members' overtime pay.  32. Further, Defendants failed to pay agreed-upon commissions to Named Plaintitls and Class Members according to tenns of their commission plan, in violation of the New York Labor Law.  33. Defendants' policy is not to ensure that it pays regular pay. overtime pay and accrued commissions to its employees according to state and federal law.  35. Defendants' policy of not properly paying its employees is long-standing and. upon information and belief, has been in effect for at least six (6) years.  36. Defendants' deprivation of proper regular pay, overtime pay and accrued commissions as required by the FLSA and New York Labor Law is willfuL  37. In addition, Defendants do not maintain accurate time records with respect to Named Plaintiffs and Class Members, as required by the FLSA and New York Labor Law. 38. Named Plaintiffs and Class Members reallege the above paragraphs as if fully restated herein.  39. Defendants willfully violated their obligations under the FLSA and are liable to Named Plaintiffs and those similarly situated. 40. Named Plaintiffs and Class Members reallege the above paragraphs as if fully restated herein.  41. Defendants willfully violated their obligations under the New York Labor Law and are liable to Named Plaintiffs and those similarly situated.