10.  Handy offers customers the ability to request and schedule a cleaner on a  mobile phone application or through its website.    12.   Cleaners are paid hourly for the time they are scheduled to spend  cleaning.  Their hourly wage may be raised or lowered depending on their performance.   Cleaners are not compensated for additional time they may spend cleaning beyond the  scheduled period of a given job or for time spent traveling between jobs.     13.  Although classified as independent contractors, Handy cleaners are  employees.  They are required to follow detailed requirements imposed on them by  Handy, and they are graded, and are subject to termination, based on Handy’ discretion  and/or their failure to adhere to these requirements (such as rules regarding how they  must perform the cleaning work, when they are permitted to cancel a job, how long they  must spend at a given job, etc.)   14.  In addition, Handy is in the business of providing cleaning service to  customers, and that is the service that Handy cleaners provide.  The cleaners’ services  are fully integrated into Handy’s business, and without the cleaners, Handy’s business  would not exist.   15.  However, based on their misclassification as independent contractors,  Handy cleaners are required to bear many of the expenses of their employment,  including expenses for their cleaning supplies.    16.  Some of these expenses for cleaning supplies are deducted from the  cleaners’ paychecks.   9.  Handy is a cleaning service that provides cleaning in cities throughout the  country via an on demand dispatch system.     Failure to Pay Minimum Wage in Violation of the FLSA  Defendant’s willful conduct in failing to ensure its employees receive the federal  minimum wage, and requiring its employees to pay for the expenses of their employment  (all of which contribute to them not receiving the federal minimum wage), violates the  FLSA, 29 U.S.C. § 201, et seq.  This claim is brought on behalf of a class of similarly  situated individuals who have worked for Handy anywhere in the country (other than  California) and may choose to “opt in” to this case, pursuant to 29 U.S.C. §216(b).   Violation of Mass. Gen. L. ch. 149 §§ 148 and 148B  As set forth above, Defendant has misclassified Handy cleaners in  Massachusetts as independent contractors, in violation of Mass. Gen. L. c. 149  § 148B.   As a result of this misclassification, cleaners have improperly been required to bear the  expenses of their employment (such as expenses for cleaning supplies), in violation of  Mass. Gen. L. c. 149 § 148. This claim is brought pursuant to M.G.L. c. 149, § 150. 