19.  In Defendant’s overzealous attempt to market its services, it placed (and continues  to place) phone calls to consumers who never provided consent to call and to consumers having  no relationship with Defendant. Defendant knowingly made (and continues to make) these  telemarketing calls without the prior express written consent of the call recipients. As such,  Defendant not only invaded the personal privacy of Plaintiff and members of the putative Class,  but also intentionally and repeatedly violated the TCPA.  20.  Defendant contacted Plaintiff on his cellular telephone number via ATDS, as  defined by 47 U.S.C. § 227(a)(1), dozens of times between August and September of 2015.  Plaintiff never consented in any manner to receive these calls to his cellular telephone.      21.  Plaintiff received all calls as described above on his cellular telephone assigned a  number ending in 0952.   22.  Plaintiff’s caller ID read “928-493-0104” whenever Defendant called his cellular  phone.     23.  Plaintiff answered several of the calls and interacted with Defendant’s automatic  dialing system, pre-recorded message menu, and, on at least one occasion, a live operator.   25.  Plaintiff has received auto-dialed marketing calls before.  Plaintiff associated the  momentary pause as a sign a computer had auto-dialed his number and then automatically routed  the call to a Defendant’s computerized messaging system once Defendant’s system recognized the  call had been answered.   26.  The automated message stated there were problems with Plaintiff’s google profile  – press #1 to speak with an agent, or #2 to be removed from the call list.    27.  Plaintiff wanted the calls to stop and did not trust Defendant’s automated option to  actually remove his number from the call list.  Therefore, on at least one occasion, Plaintiff took  steps to identify the company calling him so he could request to be removed from its call list.     28.  On an occasion when Defendant called from 928-493-0104, Plaintiff pressed “1”  to speak with an “agent” after answering the call and processing through Defendant’s automated,  pre-recorded voice system.     29.  Defendant’s automated system then routed Plaintiff to a female operator who  explained she worked for an “SEO company” Plaintiff later identified as Defendant.  Plaintiff  asked who the agent worked for and she told him she worked for “SEO Services.”  She then  provided a web address: www.seoservices.com   30.  Plaintiff then requested a call-back number.  At that point, Defendant’s agent  immediately disconnected the call.     31.  After the call, Plaintiff discovered www.seoservices.com linked back to  Defendant’s website, and is actually owned by Defendant.  Thus, Defendant directly placed the  calls to Plaintiff or hired a call center to place the calls on its behalf.      33.  Defendant continues to call Plaintiff without his express consent.   34.  It was obvious to Plaintiff that Defendant was engaged in a marketing campaign  wherein Defendant contacts a large number of consumers using an autodialer.   35.  Based on the circumstances of the calls – including but not limited to, a signature  pause before pre-recorded voice started speaking, the presence of a pre-recorded voice, and receipt  of multiple calls over a short period of time – Plaintiff believed Defendants called his cellular  telephone using an ATDS that automatically selected his number from a computer database.   36.  On information and belief, Defendant’s ATDS called Plaintiff on every occasion.   37.  Plaintiff understood the purpose of Defendant’s calls was to solicit business from  Plaintiff because Defendant indicated it could enhance his website’s presence on the internet.   38.  The telephone number Defendant called was assigned to a cellular telephone  service for which charges incur for incoming calls pursuant to 47 U.S.C. § 227(b)(1).   39.  Plaintiff is the regular carrier and exclusive user of the cellular telephone assigned  the number ending in 0952.   40.  The telemarketing calls Defendants placed to Plaintiff were an annoyance,  interfered with his work by causing him to lose time with customers, and invaded Plaintiff’s  privacy.         41.  Defendant’s calls constituted calls that were not for emergency purposes as defined  by 47 U.S.C. § 227(b)(1(A)(i).   42.  Plaintiff did not provide Defendant with prior express written consent to receive  calls to his cellular telephone utilizing an ATDS or artificial or pre-recorded voice, pursuant to 47  U.S.C. § 227 (b)(1)(A) and 47 C.F.R. § 64.1200(a)(3).     44.  Plaintiff has reason to believe Defendant has called, and continues to call,  thousands of wireless telephone customers to market their products and services.     45.  Plaintiff’s overriding interest is ensuring Defendant ceases all illegal telemarketing  practices and compensate all members of the Plaintiff Class for invading their privacy in the  manner the TCPA was contemplated to prevent.   46.  In order to redress injuries caused by Defendant’s violations of the TCPA, Plaintiff,  on behalf of himself and a class of similarly situated individuals, brings suit under the TCPA, 47  U.S.C. § 227, et seq., which prohibits certain unsolicited voice and text calls to cell phones.     47.  On behalf of the Plaintiff Class, Plaintiff seeks an injunction requiring Defendant  to cease all wireless telemarketing and spam activities and an award of statutory damages to the  class members, together with costs and reasonable attorneys’ fees.  48.  Plaintiff brings this action pursuant to Federal Rule of Civil Procedure 23(a), (b)(2),  and (b)(3) on behalf of himself and the following classes defined as follows (the “Class”):  All individuals in the United States who received a call made by or on behalf  of Defendant to the individual’s cellular telephone through the use of an  automatic telephone dialing system, or pre-recorded voice, or any other  device having the capacity to dial numbers without human intervention,  from October 16, 2013 to the date the Class is certified, where Defendant’s  records fail to indicate prior express written consent from the recipient to  make such call.   50.  This suit seeks only damages, statutory penalties, and injunctive relief for recovery  of economic injury on behalf of the Class, and it expressly is not intended to request any recovery  for personal injury and claims related thereto.     51.  Plaintiff reserves the right to expand the Class definition to seek recovery on behalf  of additional persons as warranted as facts are learned in further investigation and discovery.   52.  Plaintiff and members of the Class were harmed by Defendant’s acts in at least the  following ways: Defendant, either directly or through agents, illegally contacted Plaintiff and the  Class members via their cellular telephones by using an ATDS, thereby causing Plaintiff and the  Class members to incur certain cellular telephone charges or reduce cellular telephone time for  which Plaintiff and the Class members previously paid, and invading the privacy of Plaintiff and  the Class members.  B.  68.  Plaintiff re-alleges and incorporates by reference each preceding paragraph as  though set forth at length herein.   69.  Defendant made unsolicited and unauthorized calls using an ATDS or pre-recorded  voice to Plaintiff’s and the Class Members’ cellular telephones for the purpose of marketing  products and/or services to Plaintiff and the Plaintiff Class Members.   70.  Defendant made the calls without prior express written consent of the Plaintiff and  Plaintiff Class Members.     71.  The foregoing acts and omissions of Defendants constitutes numerous and multiple  violations of the TCPA, including but not limited to each and every one of the above-cited  provisions of 47 U.S.C. § 227, et. seq.   72.  As a result of Defendant’s violations of 47 U.S.C. § 227, et. seq., Plaintiff and the  Plaintiff Class Members are entitled to an award of $500.00 in statutory damages, for each and  every violation, pursuant to 47 U.S.C. § 227(b)(3)(B).     73.  Because Defendant had knowledge that Plaintiff and the Plaintiff Class Members  did not consent to the receipt of the aforementioned telephone solicitations, the Court should,  pursuant to 47 U.S.C. § 227(b)(3)(C), treble the amount of statutory damages recoverable by the  Plaintiff and Plaintiff Class Members.     A.  CLASS ALLEGATIONS   VIOLATIONS OF THE TELEPHONE CONSUMER PROTECTION ACT  47 U.S.C. § 227  