11.  Defendant JGAI is a real estate agency that contracts with individuals  to assist them in buying and selling properties. The calls at issue in this case were  made on behalf of, for the benefit of, and with the knowledge and approval of  26.  Plaintiff Gindin is the owner and customary user of a telephone  number ending in 4837.   27.  On January 11, 2007, Plaintiff Gindin registered his telephone number  on the National Do Not Call Registry to avoid receiving unsolicited telemarketing  calls.   28.  In or around early 2016, Gindin listed his home for sale.    29.  Later, in or around July 2016, Gindin made the decision to retain his  home and remove all sale listings.   30.  Shortly thereafter, Plaintiff began receiving non-stop telemarketing  calls from the Defendants soliciting Plaintiff to utilize their home listing and other  real estate brokerage services.   31.  All of the calls were made by associates of JGAI at the direction and  oversight of Glover. The calls all came from JGAI phone numbers as indicated on  Plaintiff’s Caller ID and all of the callers are associates of JGAI. JGAI and Glover  knew about, directed, ratified, and benefitted from the calls.   32.  Plaintiff received telemarketing calls from Defendants from a variety  of telephone numbers, including: 734-259-1278, 734-259-1121, 248-633-6947,  248-930-0198, 248-633-6947, and others.   34.  On information and belief, Defendant Sweis is the primary and  customer user of the telephone number 734-259-1278. Sweis placed at least three  known calls to Plaintiff in a twelve-month period and/or more than thirty (30) days  after Plaintiff requested to no longer be called on September 6, 2016.   35.  On information and belief, Defendant Loomis is the primary and  customer user of the telephone number 734-259-1121. Loomis placed at least two  known calls to Plaintiff in a twelve-month period and/or more than thirty (30) days  after Plaintiff requested to no longer be called on September 6, 2016.   36.  On information and belief, Defendant Bertrand is the primary and  customer user of the telephone number 248-633-6947. Bertrand placed at least  three known calls to Plaintiff in a twelve-month period and/or more than thirty (30)  days after Plaintiff requested to no longer be called on September 6, 2016.   37.  After receiving repeated telemarketing calls from Defendants, on or  around September 6, 2016, Plaintiff posted a complaint on Defendant JGAI’s  website requesting that Defendants stop all telemarketing calls to his telephone.   38.  Later that same day, September 6, 2016, Defendant Glover responded  and acknowledged Plaintiff’s request to no longer be called and further informed  Plaintiff that he would remove his name and number from Defendants’ calling list.    40.  Plaintiff received over twenty-five calls from or on behalf of JGAI  that were placed, in part, by the individual Defendants more than 30 days after  Plaintiff’s September 6, 2016 request to be placed on Defendants’ internal do not  call list.   41.  On or around August 2017, after having listed his home for sale again,  Plaintiff removed the listing for a second time.    42.  Shortly thereafter, Plaintiff was, again, flooded with calls from the  Defendants attempting solicit Plaintiff to utilize their home listing and other real  estate brokerage services.   43.  Then, on or around May 2018, having listed his home for sale a third  time, Plaintiff made the decision to change real estate agents and briefly removed  his listing.   44.  Unsurprisingly, Defendants continued to bombard Plaintiff with calls  attempting to again utilize their home listing and other real estate brokerage  services.   46.  Defendants were, and are, aware that the above-described  telemarketing calls were made to consumers like Plaintiff who have not consented  to receive them.   47.  Moreover, Defendants deliberately and intentionally refuse to honor  requests by consumers to place their numbers on Defendants’ do not call list, to the  extent it maintains any such list or has a policy regarding the maintenance of any  such list.   49.  To redress these injuries, Plaintiff, on behalf of himself and the  Classes of similarly situated individuals, brings this suit under the TCPA, which  prohibits unsolicited telemarketing calls to cellular telephones. On behalf of the  Classes, Plaintiff seek an injunction requiring Defendants to cease all unauthorized  calling activities and an award of statutory damages to the class members, together  with costs and reasonable attorneys’ fees.  51.  The following people are excluded from the Classes: (1) any Judge or  Magistrate presiding over this action and members of their families; (2)  Defendants, Defendants’ subsidiaries, parents, successors, predecessors, and any  entity in which the Defendants or their parents have a controlling interest and their  current or former employees, officers and directors; (3) persons who properly  execute and file a timely request for exclusion from the Classes; (4) persons whose  claims in this matter have been finally adjudicated on the merits or otherwise  released; (5) Plaintiff’s counsel and Defendants’ counsel; and (6) the legal  representatives, successors, and assignees of any such excluded persons. Plaintiff  anticipates the need to amend the class definitions following a period of  appropriate discovery.    52.  Numerosity: The exact number of members within the Classes is  unknown and not available to Plaintiff at this time, but individual joinder is  impracticable. On information and belief, Defendants have placed telemarketing  calls to thousands of consumers who fall into the defined Classes. However, the  exact number of members of the Classes can only be identified through  Defendants’ records, including the Defendants’ phone records.   54.  Adequate Representation: Plaintiff will fairly and adequately  represent and protect the interests of the Classes, and has retained counsel  competent and experienced in complex class actions, including cases under the  TCPA. Plaintiff has no interest antagonistic to those of the Classes, and Defendants  have no defenses unique to Plaintiff.   56.  Conduct Similar Towards All Class Members: By committing the  acts set forth in this pleading, Defendants have acted or refused to act on grounds  substantially similar towards all members of the Classes so as to render  certification of the Classes for final injunctive relief and corresponding declaratory  relief appropriate under Rule 23(b)(2).   58.  Plaintiff incorporates the foregoing allegations as if fully set forth  herein.   60.  The TCPA’s implementing regulation, 47 C.F.R. § 64.1200(c),  provides that “[n]o person or entity shall initiate any telephone solicitation” to “[a]  residential telephone subscriber who has registered his or her telephone number on  the national do-not-call registry of persons who do not wish to receive telephone  solicitations that is maintained by the federal government.”   62.  Defendants violated 47 C.F.R. § 64.1200(c) by initiating, or causing  to be initiated, telephone solicitations to telephone subscribers such as Plaintiff and  the DNC Registry Class members who registered their respective telephone  numbers on the National Do Not Call Registry. These consumers requested to not  receive calls from Defendants as set forth in 47 C.F.R. § 64.1200(d)(3).   64.  Defendants violated 47 U.S.C. § 227(c)(5) by placing more than one  call to Plaintiff and the Class in a 12-month period despite the fact Plaintiff and the  Class members’ telephone numbers were registered on the national Do Not Call  list for more than 30 days.   65.  Defendants also violated 47 C.F.R. § 64.1200(d) by initiating calls for  telemarketing purposes to residential telephone subscribers, such as Plaintiff and  the DNC Registry Class, without instituting procedures that comply with minimal  regulatory standards, including having a written policy for maintaining a list of  persons who request not to receive telemarketing calls from them, and by not  informing and training their personnel engaged in telemarketing in the existence  and use of any such do-not-call policy or list.    67.  Should the Court determine that Defendants’ conduct was willful and  knowing, the Court may, pursuant to Section 227(c)(5), treble the amount of  statutory damages recoverable by Plaintiff and the other members of the DNC  Registry Class.  68.  Plaintiff incorporates the foregoing allegations as if fully set forth  herein.   69.  Plaintiff and other members of the DNC Stop Class expressly  requested that Defendants no longer placed calls to them, after which Defendants  failed to place Plaintiff and other members of the DNC Stop Class on its internal  do not call list (or failed to do so within a reasonable time period).   70.  More than thirty days following Plaintiff and the other members of the  DNC Stop Class express stop requests to cease their receipt of future calls from  Defendants, Defendants placed additional calls to Plaintiff and the class members  without their consent and contrary to their prior requests not to be called.   72.  Defendants made these calls without instituting procedures that  comply with minimal regulatory standards, including having a written policy for  maintaining a list of persons who request not to receive telemarketing calls from  them, and by not informing and training their personnel engaged in telemarketing  in the existence and use of any such do-not-call policy or list.    73.  As a result of Defendants’ unlawful conduct, Plaintiff and the Class  suffered actual damages and, under section 47 U.S.C. § 227(c)(5), Plaintiff and  each member of the DNC Stop Class are each entitled to receive up to $500 in  damages for each violation of 47 C.F.R. § 64.1200.   74.  In the event the Court determines that Defendants’ conduct was  willful and knowing, the Court may, pursuant to Section 227(c)(5), treble the  amount of statutory damages recoverable by Plaintiff and the other members of the  DNC Stop Class.  Violation of 47 U.S.C. § 227, et seq.  (On behalf of Plaintiff and the DNC Registry Class)   Violation of 47 U.S.C. § 227, et seq.  (On behalf of Plaintiff and the DNC Stop Class)  