18.   Palmer offers and sells extended auto warranties and other  products and services to American consumers, including to Oregon  residents. Palmer generally relies on third party telemarketing agents  that it, or its sister entity NCWC, engages to execute telemarketing  campaigns by making calls to market or sell Palmer’s or NCWC’s  products and services.   20.   Palmer’s and NCWC’s telemarking campaigns have unlawfully  invaded the privacy of countless American consumers, hundreds of  which of which have submitted complaints about Palmer’s and NCWC’s  unlawful practices. See, e.g.,  https://www.bbb.org/us/nj/ocean/profile/extended-warranty-contract- service-companies/palmer-administrative-services-0221- 90163943/customer-reviews;  https://www.bbb.org/us/nj/allenhurst/profile/auto-warranty- processing/ncwc-inc-0221-11001474.   22.    The Mey Class Action resulted in a class settlement (Mey Class  Settlement), which was preliminarily approved by the court on April 6,  2017, certified a class including “[a]ll persons or entities in the United  States to whom Got Warranty, Inc., or any third parties on its behalf,  sent telemarketing calls promoting the goods or services of Defendants  [Palmer and NCWC] at any time from August 6, 2011 to February 27,  2015,” and authorized a $650,000 class settlement fund. The Mey Class  Settlement was granted final approval in a judgment entered on July  26, 2017. Mey Class Action, Doc. 149.    24.    Palmer and NCWC and their telemarketing agents have altered  their unlawful telemarketing campaigns to make it more difficult for  consumers to be able to hold them accountable, through the use of phone  number spoofing technology or similar tactics which make it nearly  impossible for the recipients to discover the identity of the caller(s)  without formal legal discovery. See https://www.fcc.gov/spoofing. These  tactics also increase Palmer and NCWC’s profits, because calls from  numbers with local area codes are much more likely to be answered by  the recipients and calls from different numbers are nearly impossible to  block.    26.             On many occasions, plaintiff answered the calls. Each and every  time she answered, she was presented with a prerecorded or artificial  voice message soliciting extended auto warranties and stating that she  should “dial 1” to speak with an operator or “dial 2” if she wanted her  number removed, or similar language.   28.       On many occasions plaintiff would not be able to answer the calls,  and on each of these occasions one of multiple versions of a prerecorded  or artificial voice message would be left on plaintiff’s voicemail. When  plaintiff listened to each these messages, she heard a prerecorded or  artificial voice consistent with the prerecorded or artificial voice  messages that played when plaintiff answered the calls, marketing  extended auto warranties.     29.         Because plaintiff’s caller identification indicated that these calls  were from different numbers, with mostly Oregon area codes, plaintiff  was unable to block the calls or to identify the caller or discern the  nature of the call, before answering the calls or listening to the messages  featuring a prerecorded or artificial voice.   31.      Plaintiff has suffered a concrete injury-in-fact and has standing  because defendants’ unlawful and unsolicited telemarketing calls using  a prerecorded or artificial voice at issue here without her consent  “present the precise harm and infringe the same privacy interests  Congress sought to protect in enacting the TCPA” and “by their nature,  invade the privacy and disturb the solitude of their recipients.” Van  Patten v. Vertical Fitness Grp., Ltd. Liab. Co., 847 F.3d 1037, 1043 (9th  Cir. 2017). Moreover, plaintiff was personally affected by these  unwanted calls as she has been frustrated and distressed by her  inability to stop the calls, and the calls have invaded her privacy and  have disrupted her daily activities and the peaceful enjoyment of her  personal and professional life.   35.   A class action is proper under FRCP 23(a) because based on  information and belief and the investigation by plaintiff’s counsel, to be  confirmed through defendants’ records, the class consists of thousands  of individuals. Therefore, joinder of all members is impracticable.    37.   Plaintiff’s claim is typical of the claims of the class members,  based on the same factual circumstances, the same statute, and the  same unlawful conduct—defendants’ unlawful telemarketing campaign  using a prerecorded or artificial voice without consent—which was  uniformly directed toward plaintiff and the other class members, and  plaintiff’s and the other class members’ statutory damages will be  calculated uniformly based on the number of calls they received.  