24.  Plaintiff brings this action on behalf of himself and on behalf of a nationwide class of  similarly situated individuals.   36.  Plaintiff incorporates by reference the foregoing allegations as though fully set forth  herein.   37.  The foregoing acts and omissions of Defendant 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.   38.  As a result of Defendant's 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).   40.  Plaintiff incorporates by reference the foregoing allegations as though fully set forth  herein.   41.  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.   42.  As a result of Defendant's knowing and/or willful violations of 47 U.S.C. § 227 et  seq., Plaintiff and the Class are entitled to an award of $1,500.00 in statutory damages, for each and  every violation, pursuant to 47 U.S.C. § 227(b)(3)(B) and 47 U.S.C. § 227(b)(3)(C).   43.  Plaintiff and the Class are also entitled to and seek injunctive relief prohibiting such  conduct in the future.  8.  Plaintiff is, and at all times mentioned herein was, a “person” as defined by 47 U.S.C.  § 153(39).    9.  Defendant is, and at all times mentioned herein was, a “person” as defined by 47  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.  