(Violations of the Telephone Consumer Protection Act, 47 U.S.C. § 227)   22.   Plaintiff brings this action individually and on behalf of and all others  similarly situated (“the Class”).   23.    Plaintiff represents, and is a member of, the Classes, consisting of:  All persons in the United States who received any unsolicited fax  advertisement on their telephone facsimile machines from Defendant or  its agents(s) and/or employee(s) within the four years prior to the filing  of the Complaint.  Defendant and its employees or agents are excluded from the Classes.  Plaintiff  does not know the number of members in the Classes, but believe the Class members  number in the thousands, if not more.  Thus, this matter should be certified as a Class  action to assist in the expeditious litigation of this matter.   24.   Plaintiff and members of the Classes were harmed by the acts of  Defendant in at least the following ways: Defendant, either directly or through its  agents, illegally contacted Plaintiff and the Class members via their telephone  facsimile machines by sending unsolicited fax advertisements.  Plaintiff and the Class  members were damaged thereby.   25.   This suit seeks only damages 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.  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.   33.   Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully set forth herein at length.   34.   At all times herein, Plaintiff was and is entitled to the rights, protections  and benefits provided under the Telephone Consumer Protection Act, 47 U.S.C. §  227.    35.   The transmission of facsimiles to Plaintiff as set forth above, violated  47 U.S.C. § 227(b)(1)(C).    36.   Based upon the foregoing, Plaintiff is entitled to statutory damages  pursuant to 47 U.S.C. §§ 227(b)(3)(B) and 227(b)(3)(C).   37.    Based upon the foregoing, Plaintiff is entitled to an Order, pursuant to  47 U.S.C. § 227(b)(3)(A), enjoining Defendant from transmitting any advertisements  in violation of 47 U.S.C. § 227(b)(1)(C). 