16.  On or about February 27, 2010, Plaintiff successfully registered his residential  cellular telephone number ending in -2220 with the National Do Not Call Registry.   17.  During or about January of 2017, Defendant began placing unsolicited  telemarketing calls to Plaintiff’s cellular telephone.   18.  Defendant contacted or attempted to contact Plaintiff from telephone number 800- 838-7132, confirmed to belong to Defendant.    19.  Defendant’s unsolicited telemarketing calls to Plaintiff constitute solicitation calls  pursuant to 47 C.F.R. § 64.1200(c)(2), as they were made in attempts to promote or sell  Defendant’s products or services.   20.  Plaintiff received at least five such unsolicited telemarketing calls from Defendant  between January and February of 2017.   21.  Plaintiff did not provide his prior express invitation or permission to Defendant to  place these solicitation telemarketing calls to his telephone.    23.  In multiple instances, Defendant placed unsolicited telemarketing calls to Plaintiff  after Plaintiff registered his telephone number ending in -2220 with the federal government’s Do  Not Call List, in violation of the TCPA, 47 U.S.C. § 227, et seq., and 47 C.F.R. § 64.1200(c).    24.  Defendant’s unsolicited telemarketing calls to Plaintiff after Plaintiff registered his  telephone number ending in -2220 with the federal government’s Do Not Call List violated 47  C.F.R. § 64.1200(c) and 47 U.S.C. § 227(c)(5).  25.  Plaintiff brings this action on behalf of himself and all others similarly situated, as  members of the proposed class defined as follows (the “Class”):   All residential telephone subscribers within the United States whose  telephone numbers were registered on the National Do-Not-Call  Registry for at least 30 days, who had not granted Defendant prior  express invitation or permission, nor had a prior established business  relationship with Defendant, or who had revoked such invitation or  permission or prior business relationship, who received more than  one solicitation call made by or on behalf of Defendant within any  12-month period, within four years prior to the filing of this  Complaint.   27.  The Class is so numerous that the individual joinder of all of its members is  impractical. While the exact number and identities of the Class members are unknown to Plaintiff  at this time and can only be ascertained through appropriate discovery, Plaintiff is informed and  believes and thereon alleges that the Class include hundreds, if not thousands of members. Plaintiff  alleges that the Class members may be ascertained by the records maintained by Defendant.   28.  This suit is properly maintainable as a class action pursuant to Fed. R. Civ. P. 23(a)  because the Class is so numerous that joinder of its members is impractical and the disposition of  their claims in the Class Action will provide substantial benefits both to the parties and to the  Court.   30.  As a residential telephone subscriber who received multiple telephone calls in a 12- month period, made by or on behalf of Defendant, without his prior express invitation or  permission and without a prior established business relationship with Defendant, after his  telephone number was registered on the National Do-Not-Call Registry for at least 30 days, within  four years prior to the filing of this Complaint, Plaintiff is asserting claims that are typical of the  Class.   31.  Plaintiff has no interest adverse or antagonistic to the interests of the other members  of the Class.   32.  Plaintiff will fairly and adequately protect the interests of the members of the Class.  Plaintiff has retained attorneys experienced in the prosecution of class actions.    33.  A class action is superior to other available methods of fair and efficient  adjudication of this controversy, since individual litigation of the claims of all Class members is  impracticable. Even if every Class member could afford individual litigation, the court system  could not. It would be unduly burdensome to the courts in which individual litigation of numerous  issues would proceed. Individualized litigation would also present the potential for varying,  inconsistent or contradictory judgments and would magnify the delay and expense to all parties,  and to the court system, resulting from multiple trials of the same complex factual issues. By  contrast, the conduct of this action as a class action presents fewer management difficulties,  conserves the resources of the parties and of the court system, and protects the rights of each Class  member. Class treatment will also permit the adjudication of relatively small claims by many Class  members who could not otherwise afford to seek legal redress for the wrongs complained of herein.    35.  Defendant has acted or refused to act in respect generally applicable to the Class,  thereby making appropriate final and injunctive relief with regard to the members of the Class as  a whole.    36.  Defendant failed to comply with the requirements of the TCPA, including but not  limited to 47 U.S.C. § 227(c), and 47 C.F.R. § 64.1200(c), as to the Class members with respect  to the above-alleged transactions.    37.  The TCPA regulations, specifically 47 C.F.R. § 64.1200(c)(2), provide 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.   38.  In multiple instances, Defendant placed solicitation telephone calls to the Class  members after the members had registered their telephone numbers with the federal government’s  Do-Not-Call Registry, and without the prior express invitation or permission of, or without a prior  established business relationship with, the recipients, in violation of the TCPA, 47 U.S.C. § 227,  et seq. and 47 C.F.R. 64.1200.   39.  The size and definition of the Class can be identified through Defendant’s records  and/or Defendant’s agents’ records.  41.  The foregoing acts and omissions of Defendant constitutes 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., including the implementing regulations of 47 C.F.R.   42.  As a result of Defendant’s negligent violations of 47 U.S.C. § 227, et seq., Plaintiff  is entitled to an award of $500.00 in statutory damages for each and every such violation of the  TCPA, pursuant to 47 U.S.C. § 227(c)(5).   43.  Plaintiff is also entitled to and seek injunctive relief prohibiting such conduct in the  future.  44.  Plaintiff incorporates all of the allegations and statements made in paragraphs 1  through 39 above as if reiterated herein.   45.  The foregoing acts and omissions of Defendant constitutes 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., including the implementing regulations  of 47 C.F.R. 64.1200(c).   46.  As a result of Defendant’s knowing and/or willful violations of 47 U.S.C. § 227, et  seq., Plaintiff is entitled to an award of up to $1,500.00 in statutory damages for each and every  such violation of the TCPA, pursuant to 47 U.S.C. § 227(c)(5).   64.1200(c).    KNOWING AND/OR WILLFUL VIOLATION OF  THE TELEPHONE CONSUMER PROTECTION ACT   NEGLIGENT VIOLATION OF  THE TELEPHONE CONSUMER PROTECTION ACT  