10.  Defendant used an “automatic telephone dialing system” as defined  by 47 U.S.C. § 227(a)(1) to place its calls to Plaintiff seeking to solicit its services.    22.  Plaintiff brings this action individually and on behalf of all others  similarly situated, as a member the two proposed classes (hereafter, jointly, “The  Classes”). The class concerning the ATDS claim for no prior express consent  (hereafter “The ATDS Class”) is defined as follows:  All persons within the United States who received any  solicitation/telemarketing  telephone  calls  from  Defendant to said person’s telephone made through the  use of any automatic telephone dialing system or an  artificial or prerecorded voice and such person had not  previously consented to receiving such calls within the  four years prior to the filing of this Complaint   23.  The class concerning the National Do-Not-Call violation (hereafter  “The DNC Class”) is defined as follows:  All persons within the United States registered on the  National Do-Not-Call Registry for at least 30 days, who  had not granted Defendant prior express consent nor had  a prior established business relationship, who received  more than one call made by or on behalf of Defendant  that promoted Defendant’s products or services, within  any twelve-month period, within four years prior to the  filing of the complaint.   8.  Beginning in or around May of 2016 and continuing through October  of 2018, Defendant contacted Plaintiff on Plaintiff’s telephone numbers ending in  in -1636 and -0106 in an attempt to solicit Plaintiff to purchase Defendant’s  services.     9.  Defendant contacted or attempted to contact Plaintiff from a telephone  number belonging to Defendant, including but not limited to (424) 282-9217.   Knowing and/or Willful Violations of the Telephone Consumer Protection  Act   47 U.S.C. §227(b)  • As a result of Defendant’s willful and/or knowing violations of 47  U.S.C. §227(b)(1), Plaintiff and the ATDS Class members are  entitled to and request treble damages, as provided by statute, up to  $1,500, for each and every violation, pursuant to 47 U.S.C.  §227(b)(3)(B) and 47 U.S.C. §227(b)(3)(C).   • Any and all other relief that the Court deems just and proper.   Knowing and/or Willful Violations of the Telephone Consumer Protection  Act   47 U.S.C. §227(c)  • As a result of Defendant’s willful and/or knowing violations of 47  U.S.C. §227(c)(5), Plaintiff and the DNC Class members are entitled  to and request treble damages, as provided by statute, up to $1,500,  for each and every violation, pursuant to 47 U.S.C. §227(c)(5).   • Any and all other relief that the Court deems just and proper.   Negligent Violations of the Telephone Consumer Protection Act  47 U.S.C. §227(b)  • As a result of Defendant’s negligent violations of 47 U.S.C.  §227(b)(1), Plaintiff and the ATDS Class members are entitled to and  request $500 in statutory damages, for each and every violation,  pursuant to 47 U.S.C.  227(b)(3)(B).   • Any and all other relief that the Court deems just and proper. 