6.12  Plaintiff and the Class Members were at all times “non-exempt” employees and eligible  to receive overtime pay pursuant to Section 207 of the FLSA.   6.15  During his employment, there were other internet installers/technicians in Texas working  for Defendants who were/are subject to the same pay policy/plan described herein,  misclassified as independent contractors, work/worked overtime hours, and were/are not  compensated in accordance with the FLSA by Defendant.  Plaintiff is also aware that  Defendants operate in other states outside of Texas where internet installers/technicians  perform the same work, are misclassified as independent contractors, and are subject to  the same policies that have been described herein.   6.13  Defendants improperly classified Plaintiff and the Class Members as independent  contractors.  Defendants still fail to pay Plaintiff and the Class Members overtime wages  and all wages earned in accordance with the FLSA.     6.14  Defendants also made improper deductions from Plaintiff’s wages for purported quality  control inspections where Plaintiff and the Class Members are penalized wrongfully, at  time for jobs they were/are not responsible for, and thus amount are deducted from their  wages earned.  Plaintiff is aware of other internet installers/technicians who are/were also  subject to deductions in which significant amounts are/were wrongfully deducted from  their wages in violation of the FLSA.   6.10  Plaintiff and Class Members do/did not have authority to hire or fire any of Defendants  employees and do not have authority to set pay.   6.12  As internet installers/technicians, Plaintiff and Class Members regularly work/worked  more than forty (40) hours per workweek.  Neither he nor any of the other Class  Members had authority to (nor did they): manage an enterprise, hire or fire other  employees, set the pay rates of other employees, create policies or procedures to govern  Defendants’ employees, handle employee grievances, determine the type of equipment or  materials that Defendants could use in its operations, enter into contracts on behalf of  Defendants or otherwise have operational control over Defendants’ business operations  and practices.  Moreover, Plaintiff and the Class Members did not perform office or non- manual work directly related to the management or general business operations of  Defendants or its customers, nor did they exercise discretion and independent judgment  with respect to matters of significance in the conduct of Defendants’ business.   6.1  Defendant Millcom is an internet installation company.   Defendant Perfect 10 is a  privately owned telecommunications company.    6.2  Plaintiff worked as an internet technician/installer for Defendants.  He worked for  Defendants from February 2017 to July 24, 2019.     6.2  Defendant Anthony Miller owns Defendant Millcom and supervised Plaintiff and the  Class Members, determined their classification as independent contractors, determined  their rate of pay, made decisions as to hiring and firing, and day to day operations.   6.3.  Plaintiff was classified as an independent contractor by Defendants.  He did not receive  overtime compensation however he was expected to work over forty (40) hours per week  (and did in fact work over forty (40) hours per week) during that time period.      6.4  The other internet installers/technicians that Plaintiff worked with also work/worked over  forty (40) hours per week and did not receive overtime compensation in accordance with  the FLSA.   6.5  Due to the high volume of work, Plaintiff was often required to work long hours (over 40  hours per work week).  Defendants were aware that Plaintiff and the Class Members  work/worked over forty hours per work week to meet Defendants’ business needs.   6.5  Defendants controlled all the conditions of Plaintiff’s employment.  Defendants  determined Plaintiff’s pay rate, the schedule he worked, the tools he was required to  purchase and the policies and procedures Plaintiff and the other Class Members are/were  required to follow.   6.6  Defendants also required Plaintiff and the Class Members log in to a mobile app called  FSM Mobile.  All internet installers/technicians who worked for Defendants were  required to log in to the FSM Mobile app and Defendants used this to track their work,  locations and jobs throughout the day.     6.7  As an internet installer/technician, Plaintiff’s primary duties included, installing internet  service in customers’ homes.  Plaintiff and the Class Members were required to install the  internet antenna and modem, run cables to the modem and activate the internet service  including assisting customers with setting up their logins and passwords.  Plaintiff and  the Class Members were also required to video call a Perfect 10 representative and/or  upload pictures of their work into an app for approval.    Plaintiff and the Class Members  were also required to attend meetings approximately once a month.  These meetings were  mandatory and could last up to three (3) hours.   Plaintiff and the Class Members were  not compensated for these meetings and if they did not attend, they could face  termination or not receive any more work from Defendants.   6.9  Plaintiff and the Class Members do/did not have the authority to make unilateral  decisions regarding the work assigned by Defendants.  Plaintiff and the Class Members  could/cannot arbitrarily make changes to anything without Defendants’ approval.   7.  7.2   Defendants classified/classifies as independent contractors and paid/pays all of its  internet installers/technicians in the manner described above.  Defendants maintain a  common pay practice or policy and the Class Members are similarly situated to Plaintiff.   7.3  Defendants’ internet installers/technicians all performed the same/similar essential job  functions and duties, notwithstanding the fact that one employee might have more tenure  or experience than another employee in the same or similar position.  Therefore, the Class  Members are similarly situated to Plaintiff.     7.4  The damages for each individual can easily be calculated using the same methodology  and formula although the exact amount of the damages may vary.   8.  INC.  d/b/a  PERFECT  10  and 