25. Plaintiff brings this action under Fed. R. Civ. P. 23 on behalf of a proposed  class defined as:   Plaintiff and all persons within the United States, within  the four years immediately preceding the filing of this  Complaint, Defendant or some person acting on  Defendant’s behalf sent a text message to their cellular  telephone advertising Defendant’s political campaign,  through the use of the same or materially similar telephone  dialing equipment as that which was used to send the texts  at issue to the Plaintiff.   (the “Class”)    26. Excluded from this class are Defendant and any entities in which Defendant  have a controlling interest; Defendant’s agents and employees; any Judge and  Magistrate Judge to whom this action is assigned and any member of their  staffs and immediate families; and any claims for personal injury, wrongful  death, and/or emotional distress.   27. The Class members for whose benefit this action is brought are so numerous  that joinder of all members is impracticable.   29. The Class is comprised of hundreds, if not thousands, of individuals  nationwide.    31. As a person that received at least one unsolicited text message without  Plaintiff’s prior express written consent, Plaintiff is asserting claims that are  typical of the Class. Plaintiff will fairly and adequately represent and protect  the interests of the Class in that Plaintiff has no interests antagonistic to any  member of the Class.    32. Plaintiff and the members of the Class have all suffered irreparable harm as a  result of the Defendant’s unlawful and wrongful conduct. Absent a class  action, the Class will continue to face the potential for irreparable harm. In  addition, these violations of law will be allowed to proceed without remedy  and Defendant will likely continue such illegal conduct. Because of the size  of the individual Class member’s claims, few, if any, Class members could  afford to seek legal redress for the wrongs complained of herein.   34. Plaintiff has no interests antagonistic to, or in conflict with, the Class.    35. Plaintiff has retained counsel experienced in handling class action claims and  claims involving violations of the Telephone Consumer Protection Act.   36. Defendant has acted and refused to act on grounds generally applicable to the  Class, thereby making injunctive and declaratory relief appropriate for the  Class as a whole.    37. The prosecution of separate actions by individual class members would create  a risk of inconsistent or varying adjudications.    38. A class action is superior to other available methods for the fair and efficient  adjudication of the controversy since, inter alia, the damages suffered by each  class member make individual actions uneconomical.   39. Plaintiff incorporates by reference paragraphs one (1) through thirty-nine (39)  of this Complaint as though fully stated herein.   39. Common questions will predominate, and there will be no unusual  manageability issues.  40. The foregoing acts and omissions of Defendant 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.   41. Defendant sent text messages to Plaintiff and Class members on their cellular  telephone numbers.    42. Plaintiff and the Class are also entitled to and seek injunctive relief prohibiting  such conduct in the future.  42. The text messages were sent using an “automatic telephone dialing system.”    43. The text messages were not sent for “emergency purposes” as defined by 47  U.S.C. § 227(b)(1)(A)(i).    43. As a result of Defendant’s negligent violations of 47 U.S.C. § 227(b)(1),  Plaintiff seeks for himself and each Class member $500.00 in statutory  damages, for each and every violation, pursuant to 47 U.S.C. § 227(b)(3)(B).   44. Plaintiff and Class members 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).   44. Pursuant to 47 U.S.C. § 227(b)(3)(A), injunctive relief prohibiting such  conduct in the future.   45. An award of reasonable attorneys’ fees and costs.   46. Any other relief the Court may deem just and proper.  48. Pursuant to 47 U.S.C. § 227(b)(3)(A), injunctive relief prohibiting such conduct in the future.   49. An award of reasonable attorneys’ fees and costs.  50. Any other relief the Court may deem just and proper. 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(B)(1)(A)(III)   TCPA, 47 U.S.C. § 227 ET SEQ.   VIOLATIONS OF THE TCPA, 47 U.S.C. § 227 ET SEQ.  