In calculating the amount in controversy for a CAFA removal of a state court complaint that does not allege an amount in controversy, the defendant must provide evidence to support portions of the calculations that it is likely to be able to prove, such as the number of nonexempt employees in a wage and hour case. However, for parts of the calculation which are in the plaintiff’s possession, such as rate of alleged violation of wage and hour laws, the defendant may rely on a reasonable interpretation of the complaint’s allegations. For example, in this case the complaint alleged that the employer “at times” violated California’s meal break and overtime compensation laws. The defendant reasonably interpreted that to mean once a week per employee for each of those violations. The fact that there could be other reasonable interpretations of the complaint’s allegation regarding violation frequency did not undercut the defendant’s interpretation. Nor was the defendant required to produce evidence to support its assumed violation rate.