14.  Defendant Arms buys and sells real estate.   15.  Defendant Concentra, Inc. provides occupational therapy services at clinics nationwide.   16.  To increase their marketing efforts, Defendants texted hundreds or possibly thousands of  phones at once.     17.  Unfortunately, Defendants failed to obtain consent from Plaintiff and the Class before  sending the text messages.  18.  On May 13, 2019 at 7:55 a.m., Plaintiff received a text from Defendant Concentra and/or  their agents from the phone number 650-201-7381.   19.  The text message that Plaintiff received said “Are you looking for a new career?   Concentra is inviting physical therapists to interview for o/p ortho positions across CA and offering up  to $10k in incentives for select locations.  Grow your skills with opps for leadership, manual therapy  cert. and student teaching.  Let’s talk today!  Text STOP to end.”   21.  The text message that Plaintiff received said “11.6 CAP, Cheap Cashflow w/ Easy Fix –  Brick/Frame – 3bd/1ba, 1020sqft, Call Jason for details + pics.  901-350-5059.”   22.  Plaintiff never consented to receive text messages from Defendants.    23.  Class Definition: Plaintiff brings this action pursuant to Federal Rule of Civil Procedure  23(b)(3) on behalf of Plaintiff and a class defined as follows:  No Consent Class.  All persons in the United States who: (1) from the last 4  years to present (2) received at least one text message; (3) on his or her cellular  telephone; (4) that was texted using an automatic telephone dialing system; (5)  for the purpose of promoting Defendants’ services; (6) where Defendants did  not have any record of prior express written consent to place such call at the  time it was made.   24.  The following people are excluded from the Class: (1) any Judge or Magistrate presiding  over this action and members of their families; (2) Defendants, Defendants’ subsidiaries, parents,  successors, predecessors, and any entity in which the Defendants or their parents have a controlling  interest and its current or former employees, officers and directors; (3) persons who properly execute  and file a timely request for exclusion from the Class; (4) persons whose claims in this matter have  been finally adjudicated on the merits or otherwise released; (5) Plaintiff’s counsel and Defendants’  counsel; and (6) the legal representatives, successors, and assigns of any such excluded persons.   25.  Numerosity: The exact number of the Class members is unknown and not available to  Plaintiff, but it is clear that individual joinder is impracticable. On information and belief, Defendants  placed telephone calls to thousands of consumers who fall into the definition of the Class. Members of  the Class can be identified through Defendants’ records.   27.  Adequate Representation: Plaintiff will fairly and adequately represent and protect the  interests of the other members of the Class. Plaintiff’s claims are made in a representative capacity on  behalf of the other members of the Class. Plaintiff has no interests antagonistic to the interests of the  other members of the proposed Class and is subject to no unique defenses. Plaintiff has retained  competent counsel to prosecute the case on behalf of Plaintiff and the proposed Class.  Plaintiff and  Plaintiff’s counsel are committed to vigorously prosecuting this action on behalf of the members of the  Class and have the financial resources to do so.    28.  Policies Generally Applicable to the Class: This class action is appropriate for  certification because Defendants have acted or refused to act on grounds generally applicable to the  Class as a whole, thereby requiring the Court’s imposition of uniform relief to ensure compatible  standards of conduct toward the Class members and making final injunctive relief appropriate with  respect to the Class as a whole. Defendants’ practices challenged herein apply to and affect the Class  members uniformly, and Plaintiff’s challenge of those practices hinge on Defendants’ conduct with  respect to the Class as a whole, not on facts or law applicable only to Plaintiff.   29.  Commonality and Predominance: There are many questions of law and fact common to  the claims of Plaintiff and the Class, and those questions predominate over any questions that may  affect individual members of the Class. Common questions for the Class include, but are not  necessarily limited to the following:  i.  Whether Defendants’ conduct violated the TCPA;  ii.  Whether Defendants’ conduct violated the TCPA willingly and/or knowingly;  iii.  Whether Defendants texted thousands of cell phones;  iv.  Whether Defendants obtained prior written consent prior to texting any members of the  Class;  v.  Whether members of the Class are entitled to treble damages based on the knowingness  or willfulness of Defendants’ conduct.   31.  Plaintiff incorporates the foregoing allegations as if fully set forth herein.   32.  Defendants and/or their agents sent text messages to Plaintiff’s and the Class members’  cellular telephones without having their prior express written consent to do so.   33.  Defendants used an automatic telephone dialing system as proscribed by 47 U.S.C.  §227(b)(1)(A)   34.  Defendants’ calls were made for a commercial purpose.   35.  As a result of its unlawful conduct, Defendants repeatedly invaded Plaintiff’s and the  Class’s personal privacy, causing them to suffer damages and, under 47 U.S.C. § 227(b)(3)(B), entitling  them to recover $500 in civil fines for each violation and an injunction requiring Defendants to stop  their illegal calling campaign.   36.  Defendants and/or its agent made the violating calls “willfully” and/or “knowingly” under  47 U.S.C. § 227(b)(3)(C).   Violation of 47 U.S.C. § 227  (On behalf of Plaintiff and the Class)  