12.  Defendant placed and continues to place repeated and harassing phone calls to  consumers who allegedly owe a debt held by Defendant, or held by a third party on whose behalf  Defendant is acting, and who never provided the number called to Defendant or the third party.   Instead, Defendant acquires phone numbers through various means such as “skip tracing” or  “number trapping.”   13.  Defendant has placed calls for the purpose of debt collection to tens of thousands  of consumers in the recent past.   14.  In or around 2002, Plaintiff purchased a cellular telephone from Verizon. The  cellular telephone did not work properly and, within one month of her purchase, Plaintiff  returned the phone and did not purchase another.   15.  In or around 2012, a debt of $1,026 appeared on Plaintiff’s credit report from  Verizon.  This debt incorrectly stems from Plaintiff’s 2002 Verizon purchase.  Plaintiff does not  owe any money to Verizon associated with her purchase of a cellular telephone.   16.  Approximately three months after Plaintiff noticed the debt on her credit report,  the debt became associated with Pinnacle Credit Services instead of Verizon.   27.  Plaintiff incorporates by reference the foregoing allegations as if fully set forth  herein.   28.  Defendant and/or its agents made unsolicited telephone calls to cellular telephone  numbers belonging to Plaintiff and the other members of the Class without their prior express  consent to receive such calls.   29.  Defendant made the telephone calls, or had them made on its behalf, using  equipment that had the capacity to store or produce telephone numbers to be called using a  random or sequential number generator, and to dial such numbers.   Violation of the TCPA, 47 U.S.C. § 227  (on behalf of Plaintiff and the Class)  