27. Plaintiff brings this action on behalf of himself and on behalf of and Class  Members of the proposed Class pursuant to Federal Rules of Civil  Procedure 23(a) and (b)(3) and/or (b)(2).    39.  Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   40.  Defendant’s repeated calls to Plaintiff’s cellular phone without any prior  express consent constitute numerous and multiple negligent 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.   41.  As a result of Defendant’s, and Defendant’s agents’ negligent violations of  47 U.S.C. § 227, et seq., Plaintiff and the Class 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).   43.  Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   44.  Defendant made repeated telephone calls to Plaintiff’s cellular telephone  without being in any business relationship or contract.    45.  Defendant’s actions constitute numerous and multiple knowing and/or  willful 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.   46.  As a result of Defendant’s knowing and/or willful violations of 47 U.S.C.  § 227, et seq., Plaintiff and each of the Class members are entitled to treble  damages, as provided by statute, up to $1,500.00, for each and every  violation, pursuant to 47 U.S.C. § 227(b)(3)(B) and 47 U.S.C. §  227(b)(3)(C).    47.  Plaintiff and the Class members are also entitled to and seek injunctive  relief prohibiting such conduct in the future.  KNOWING AND/OR WILLFUL VIOLATIONS OF THE   TELEPHONE CONSUMER PROTECTION ACT   47 U.S.C. § 227 ET SEQ.   NEGLIGENT VIOLATIONS OF THE  TELEPHONE CONSUMER PROTECTION ACT  47 U.S.C. § 227 ET SEQ.   OF THE TCPA, 47 U.S.C. § 227 ET SEQ.  •  As a result of Defendant and Defendant’s agent’s willful and/or knowing  violations of 47 U.S.C. § 227(b)(1), Plaintiff seeks for himself and each  Class member treble damages, as provided by statute, up to $1,500.00 for  each and every violation, pursuant to 47 U.S.C. § 227(b)(3)(B) and 47  U.S.C. § 227(b)(3)(C).  •  Pursuant to 47 U.S.C. § 227(b)(3)(A), injunctive relief prohibiting such  conduct in the future.  • Costs of suit.  • Attorneys’ fees pursuant to, inter alia, the common fund doctrine.  • Any other relief the Court may deem just and proper. 