18.  Portfolio Recovery Associates, L.L.C. is a debt collection company and operates  several call centers throughout the United States.2   19.  Plaintiff and the Putative Class Members’ job duties consisted of making and  answering phone calls made by debtors, and would attempt to collect on these outstanding debts.   20.  Plaintiff Scott was employed by PRA in customer service in Hampton, Virginia from  approximately November 2017 until February 2020.   21.  Plaintiff and the Putative Class Members are non-exempt call-center employees who  were (and are) paid by the hour.   22.  Plaintiff and the Putative Class Members typically worked approximately forty (40)  “on-the-clock” hours per week.   23.  In addition to their forty (40) “on-the-clock” hours, Plaintiff and the Putative Class  Members worked up to five (5) hours “off-the-clock” per week and have not been compensated for  that time.   24.  Plaintiff and the Putative Class Members have not been compensated for all the hours  they worked for PRA as a result of PRA’s corporate policy and practice of requiring their hourly call- center employees to clock-in only when ready to take their first call.    26.  If Plaintiff and the Putative Class Members are not ready and on the phone at shift  start they can be subject to discipline.    27.  If Plaintiff and the Putative Class Members clock in prior to their shift start time, they  are also subject to discipline.    28.  Therefore, the only way to be ready on time, and avoid discipline, is to prepare the  computer “off-the-clock.”    29.  During this start up time, Plaintiff and the Putative Class Members were not  compensated although they were expected to have completed this process in advance of their official  start times.   30.  PRA provides the Plaintiff and the Putative Class Members with one unpaid lunch  break per shift.    31.  However, PRA requires the Plaintiff and the Putative Class Members to perform “off- the-clock” work during their unpaid lunch break.   32.  Plaintiff and the Putative Class were required to stay on the clock and on call until the  minute their lunch break began, clock out, then log out of the phone system or otherwise go into an  aux mode, and then log off of their computer prior to leaving their desk for lunch.    33.  Plaintiff and the Putative Class Members were required to log back into their  computer, log back into the phone system, then clock in, and be back on the phone right at the  moment their lunch break ends.    34.  The log off process used prior to going to lunch can take 1-3 minutes.    36.  This lengthy log off and log in procedure had to be performed during Plaintiff and the  Putative Class Members’ lunch break per PRA policy.    37.  Further, Plaintiff and the Putative Class Members’ computers crashed multiple times  each week and required Plaintiff and the Putative Class Members to reset them, which took ten (10)  minutes or more each time.    38.  Plaintiff and the Putative Class Members were also not compensated for the time they  worked for PRA rebooting PRA’s computers after they crashed.    39.  Plaintiff and the Putative Class Members were always scheduled to work exactly forty  (40) hours each week.    40.  Plaintiff and the Putative Class Members were (and still are) not permitted to hang up  on customers and must finish every call regardless of how long it takes.   41.  Plaintiff and the Putative Class Members frequently found (and continue to find)  themselves handling calls past the end of their shift end time on the last day of the week.    42.  This call would cause Plaintiff and the Putative Class Members to go over their forty  (40) hour work shift in one week. However, PRA would shave that time off and not pay Plaintiff and  the Putative Class Members any overtime.    43.  In addition, PRA also enforced a uniform company-wide policy wherein they  improperly required their non-exempt hourly employees—Plaintiff and the Putative Class Members— to clock out for rest breaks lasting twenty minutes or less. 29 C.F.R. § 785.18; see also Sec’y U.S. Dep’t  of Labor v. Am. Future Sys., Inc., 873 F.3d 420, 425 (3d Cir. 2017).   45.  As a result of PRA’s corporate policy and practice of requiring Plaintiff and the  Putative Class Members to perform their computer start up tasks before the beginning of their shifts,  perform log-in log out processes during their unpaid lunch break, and requiring Plaintiff and the  Putative Class Members to clock out for short breaks, Plaintiff and the Putative Class Members were  not compensated for all hours worked, including all worked in excess of forty (40) in a workweek at  the rates required by the FLSA.    46.  PRA has employed other individuals who perform(ed) the same or similar job duties  under the same pay provisions as Plaintiff.   47.  PRA is aware of their obligation to pay overtime for all hours worked and the proper  amount of overtime for all hours worked in excess of forty (40) each week, but have failed to do so.    48.  Because PRA did not pay Plaintiff and the Putative Class Members for all hours  worked and time and a half for all hours worked in excess of forty (40) in a workweek, PRA’s pay  policies and practices violate the FLSA.   V.  49.  Plaintiff Scott incorporates by reference all paragraphs and allegations set forth in the  statement of facts of this complaint as though fully and completely set forth herein.   50.  The FLSA Collective is defined as:  66.  All previous paragraphs are incorporated as though fully set forth herein.   67.  Pursuant to 29 U.S.C. § 216(b), this is a collective action filed on behalf of all of PRA’s  employees who have been similarly situated to Plaintiffs with regard to the work they performed and  the manner in which they have not been paid.   68.  Other similarly situated employees of PRA have been victimized by PRA’s patterns,  practices, and policies, which are in willful violation of the FLSA.   69.  The FLSA Collective Members are defined in Paragraph 50.   70.  PRA’s failure to pay Plaintiff and the FLSA Collective Members for all hours worked  and overtime compensation at the rates required by the FLSA, results from generally applicable  policies and practices of PRA, and does not depend on the personal circumstances of Plaintiff or the  FLSA Collective Members.    71.  Thus, Plaintiff’s experiences are typical of the experiences of the FLSA Collective  Members.   72.  The specific job titles or precise job requirements of the various FLSA Collective  Members do not prevent collective treatment.    73.  All of the FLSA Collective Members—regardless of their specific job titles, precise job  requirements, rates of pay, or job locations—are entitled to be paid for all hours worked and at the  proper overtime rate for all hours worked in excess of forty (40) hours per workweek.    74.  Although the issues of damages may be individual in character, there is no detraction  from the common nucleus of liability facts.     76.  Moreover, individual litigation would be unduly burdensome to the judicial system.  Concentrating the litigation in one forum will promote judicial economy and parity among the claims  of the individual members of the classes and provide for judicial consistency.   77.  Accordingly, the FLSA collective of similarly situated plaintiffs should be certified as  defined as in Paragraph 50 and notice should be promptly sent.   VI.  A.  FLSA COVERAGE  