11.  HP employed Plaintiffs and members of the Collective Action Class in the  Services Information Development, Technical Consulting, and ITO Service Delivery job families  at HP’s locations within the United States.   12.  Plaintiffs and the Collective Action Class regularly worked in excess of 40 hours  per workweek without receiving the legally required amount of overtime wages from HP for all  hours worked by them as required by the FLSA.   13.  Plaintiffs and the Collective Action Class primarily performed non-exempt job  duties and, therefore, HP misclassified them as exempt from the FLSA.  Plaintiffs and the  Collective Action Class did not perform work directly related to management policies or general  business operations and did not customarily and regularly exercise discretion and independent  judgment.     15.  HP maintained a uniform policy or practice of willfully failing to pay Plaintiffs  and the Collective Action Class for all hours worked in a workweek including overtime.   16.  HP also failed to maintain accurate and sufficient timekeeping records in  compliance with the FLSA.   17.  HP’s failure to comply with the FLSA caused Plaintiffs and the Collective Action  Class members to suffer lost wages and interest thereon.   18.  All actions and omissions described in this Complaint were made by HP directly  or through its supervisory employees and agents.  19.  Plaintiffs bring this lawsuit pursuant to 29 U.S.C. § 216(b) as a collective action  on behalf of the Collective Action Class, as defined above.   20.  Plaintiffs desire to pursue their FLSA claims on behalf of any individuals who opt  in to this action pursuant to 29 U.S.C. § 216(b).   21.  Plaintiffs and the Collective Action Class are “similarly situated” as that term is  used in 29 U.S.C. § 216(b), because, inter alia, all such individuals worked pursuant to  Defendant’s previously described common business policies and practices and, as a result of  such policies and practices, were not paid the full and legally mandated overtime premium for  hours worked over forty during the workweek.  Defendant also failed to pay Plaintiffs and all  Collective Action Members overtime compensation on a timely basis in violation of the FLSA.   Resolution of this action requires inquiry into common facts, including, inter alia, Defendant’s  common compensation, timekeeping and payroll practices.   23.  Plaintiffs reallege and incorporate by reference the preceding paragraphs.   24.  At all relevant times, Defendant has been and continues to be, an employer  engaged in interstate commerce and/or the production of goods for commerce, within the  meaning of the FLSA, 29 U.S.C. §§ 206(a) and 207(a).    25.  At all relevant times, Defendant employed, and/or continues to employ, Plaintiffs  and each of the Collective Action Class members within the meaning of the FLSA.   26.  At all relevant times, Defendant has had annual gross revenues exceeding  $500,000.   28.  As a result of Defendant’s willful failure to compensate Plaintiffs and the  Collective Action Class members at a rate not less than one and one-half times the regular rate of  pay for work performed in excess of 40 hours in a workweek, Defendant has violated and  continues to violate the FLSA, 29 U.S.C. §§ 201 et seq., including 29 U.S.C. §§ 207(a)(1) and  215(a).   29.  Defendant has failed to make, keep and preserve records with respect to Plaintiffs  and the Collective Action Class members sufficient to determine their wages, hours and other  conditions and practices of employment in violation of the FLSA, 29 U.S.C. §§ 201, et seq.,  including 29 U.S.C. §§ 211(c) and 215(a).   30.  Defendant’s conduct as alleged herein constitutes a willful violation of the FLSA  within the meaning of 29 U.S.C. § 255(a).   31.  Due to Defendant’s FLSA violations, Plaintiffs and the Collective Action Class  members are entitled to recover from Defendant their unpaid wages for the legally required  amount of overtime compensation for all of the hours worked by them in excess of forty in a  workweek, actual and liquidated damages, including the employer’s share of FICA, FUTA, state  unemployment insurance, and any other required employment taxes, reasonable attorneys’ fees  and costs and disbursements of this action, pursuant to 29 U.S.C. § 216(b).  FAIR LABOR STANDARDS ACT  