10.  Upon information and belief, other similarly situated employees are also uniformly paid  in a fashion similar to Plaintiff and not compensated for the expenses associated with performing  their job duties.   11.  As a matter of economic reality, DoorDash advertises, on the "About Us" section of its  website, that "through the DoorDash marketplace, people can purchase goods from local  merchants and have them delivered in less than 45 minutes—thanks to our revolutionary  logistics technology."   Specifically, DoorDash is in the business of delivering goods to its  customers—the very task that drivers are hired to perform.  The work performed by drivers is  integral to Defendant's business in that DoorDash simply could not function without its drivers.   13.  Defendant did not pay Plaintiff and others similarly situated one-and-one-half times their  regular rates of pay for hours worked in excess of forty (40) per week.   14.  Defendant violated the FLSA because it did not pay Plaintiff and others similarly situated  the overtime pay they should have received for the hours worked in excess of forty (40) in a  workweek.  Plaintiff and others similarly situated did not receive minimum wage for hours  worked for DoorDash.   15.  As a result, Plaintiff and others similarly situated did not receive compensation they were  legally entitled to receive.  The work performed by Plaintiff and others similarly situated was  with Defendant's knowledge.  Defendant approved driver's schedules, assigned work and  supervised the work.   16.  Defendant's violations of the FLSA were committed knowingly, willfully, and/or with  reckless disregard to Plaintiff and similarly situated employees' rights.  V.  17.  Plaintiff reasserts and incorporate by reference all of the above numbered paragraphs.   18.  Plaintiff and others similarly situated were employees of DoorDash, Inc., as set forth  above.   19.  As employees of DoorDash, Plaintiff and others similarly situated were legally entitled to  be paid at one-and-one-half times their regular rates of pay for hours worked in excess of forty  (40) hours per each seven (7) day workweek. As employees of DoorDash, Plaintiff and others  similarly situated were legally entitled to minimum wage.   21.  As a result, Plaintiff and others similarly situated did not receive the compensation they  were legally entitled to receive.    22.  Defendant's violations of the FLSA were committed knowingly, willfully, and/or with  reckless disregard to Plaintiff's and other similarly situated employees’ rights.    23.  As a result of Defendant's willful violations of the FLSA, Plaintiff and others similarly  situated are entitled to reimbursement of unpaid overtime, an additional equal amount as  liquidated damages, and reasonable attorneys fees, costs and disbursements incurred in this  action pursuant to 29 U.S.C. § 216(b).  VI.  24.  Plaintiff reasserts and incorporate by reference all of the above numbered paragraphs.   25.  The FLSA requires employers to keep accurate records of hours worked by nonexempt  employees.  29 U.S.C. §211(c); 29 C.F.R. pt 516.   26.  In addition to the pay violations of the FLSA described above, Defendant also failed to  keep proper time records as required by the FLSA.  27.  Plaintiff reasserts and incorporate by reference all of the above numbered paragraphs.   28.  Upon information and belief, many other similarly situated employees employed by  Defendant over the last three (3) years have been victimized by Defendant's violations of the  3.  At all times relevant to this lawsuit, Defendant was, and remains, an enterprise engaged  in commerce or in the production of goods for commerce within the meaning of the FLSA. 29  U.S.C. § 203, and is subject to the FLSA.   4.  At all times relevant to this lawsuit, Defendant was, and remains, an enterprise engaged  in commerce or in the production of goods for commerce within the meaning of the FLSA. 29  U.S.C. § 203, and is subject to the FLSA.   5.  Defendant, DoorDash, Inc. is a food delivery service that allows customers to place food  orders, through a mobile phone application or through its website, from various restaurants in the  "DoorDash marketplace". DoorDash, Inc. then utilizes its "Dashers" (i.e. delivery drivers) to  deliver those food orders to its customer's homes or businesses.     6.  Defendant employed Plaintiff and others similarly situated at all relevant times within the  meaning of the FLSA. 29 U.S.C. § 203(g).  Defendant's annual revenues far exceeded $500,000  during the relevant time period.   7.  In performing his duties for Defendant, Plaintiff and others similarly situated were  employed in an enterprise engaged in commerce or in the production of goods for commerce.  Specifically, Defendant has employees utilizing interstate telephone and broadband  communications for the commercial purposes of Defendant's enterprise.  Moreover, Defendant  required that Plaintiff regularly travel through the corridors of interstate commerce as they  traveled from customer to customer to make deliveries.   9.  Plaintiff and others similarly situated are paid a flat fee for every delivery completed plus  gratuity added by the customer.  Often drivers do not make minimum wage for every hour  worked during their shifts.  DoorDash does not compensate drivers for the expenses associated  with using their own vehicles, cell phone data, car insurance (though a requirement of  employment if you use a car to make deliveries), gas, parking, and other expenses.    