15.  Plaintiff is, and at all times mentioned herein was, a “person” as defined by 47  U.S.C. § 153(39).   16.  Beginning in or around November of 2018, Plaintiff began receiving numerous  autodialed and pre-recorded calls on her cellular phone ((XXX) XXX-2511) from ARM. When  Plaintiff did not pick up the phone, ARM left a prerecorded voicemail informing her that it  was ARM calling and that Plaintiff should call ARM back at 888-548-8829. There was at least  one number that appeared in Plaintiff’s caller ID for these calls: 888-548-8829. This number  appears to be associated with ARM.  Most recently, Plaintiff received calls from ARM at this  number on December 10, 2018 at 12:50 PM and December 18, 2018 at 3:07 PM.   17.  Plaintiff requested that the calls stop many times. ARM continued to call her  cellular phone anyway.    18.  ARM is, and at all times mentioned herein was a “person”, as defined by 47  26.  Plaintiff brings this action on behalf of herself and on behalf of all other persons  similarly situated (hereinafter referred to as “the Class”).   27.  Plaintiff proposes the following Class definitions, subject to amendment as  appropriate:  All persons in the United States who received a call from ARM from an automated  telephone dialing system and/or utilizing a prerecorded voice on or after November  1, 2014, for whom ARM cannot provide evidence that the Class member provided  ARM his or her cellular telephone number.  Collectively, all these persons will be referred to as “Class members.” Plaintiff represents, and is  a member of, the Class. Excluded from the Class are Defendant and any entities in which  Defendant has a controlling interest, Defendant’s agents and employees, any Judge to whom this  action is assigned and any member of such Judge’s staff and immediate family, and claims for  personal injury, wrongful death and/or emotional distress.    29.  Plaintiff does not know the exact number of members in the Class or Subclass, but  on information and belief, the number of Class and Subclass members at minimum is in the  thousands.    30.  Plaintiff and all members of the Class and Subclass have been harmed by the acts  of Defendant, including, but not limited to, the invasion of their privacy, annoyance, waste of time,  depletion of their cellular phone battery, and the intrusion on their cellular telephone that occupied  it from receiving legitimate communications.    31.  This Class Action Complaint seeks injunctive relief and money damages.    32.  The joinder of all Class and Subclass members is impracticable due to the size and  relatively modest value of each individual claim. The disposition of claims in a class action will  provide substantial benefit to the parties and the judicial economy of the Court in avoiding a  multiplicity of identical suits. The Class and Subclass can be identified easily through records  maintained by Defendant.    51.  As a person who received numerous and repeated telephone calls using an  automatic telephone dialing system and an artificial or prerecorded voice, without her prior express  consent within the meaning of the TCPA and Rules, Plaintiff asserts claims that are typical of each  Class and Subclass member. Plaintiff will fairly and adequately represent and protect the interests  of the Class and Subclass, and has no interests which are antagonistic to any member of the Class  or Subclass.    52.  Plaintiff has retained counsel experienced in handling class action claims involving  violations of federal and state consumer protection statutes, including claims under the TCPA.    54.  Defendant has acted on grounds applicable to the Class and Subclass, thereby  making final injunctive relief and corresponding declaratory relief with respect to the Class and  Subclass as a whole appropriate. Moreover, on information and belief, Plaintiff alleges that the  TCPA violations complained of herein are substantially likely to continue in the future if an  injunction is not entered.  55.  Plaintiff incorporates by reference the foregoing paragraphs of this Complaint as if  fully stated herein.   56.  The foregoing acts and omissions of ARM constitute numerous and multiple  knowing and/or willful violations of the TCPA, including but not limited to each of the above cited  provisions of 47 U.S.C. § 227, et seq.   57.  As a result of Defendant’s knowing and/or willful violations of 47 U.S.C. § 227 et  seq., Plaintiff and each member of the Class and Subclass are entitled to treble damages of up to  $1,500.00 for each and every violation of the statute, pursuant to 47 U.S.C. § 227(b)(3).   59.  Plaintiff incorporates by reference the foregoing paragraphs of this Complaint as if  fully set forth herein.   60.  The foregoing acts and omissions of Defendant constitute numerous and multiple  violations of the TCPA, including but not limited to each of the above-cited provisions of 47 U.S.C.  § 227 et seq.   61.  As a result of Defendant’s violations of 47 U.S.C. § 227 et seq., Plaintiff and Class  and Subclass members are entitled to an award of $500.00 in statutory damages for each and every  violation of the statute, pursuant to 47 U.S.C. § 227(b)(3)(B).    62.  Plaintiff and Class and Subclass members are also entitled to and do seek injunctive  relief prohibiting Defendant’s violation of the TCPA in the future.   KNOWING AND/OR WILLFUL VIOLATIONS OF THE TELEPHONE CONSUMER  PROTECTION ACT, 47 U.S.C. § 227, ET SEQ.   MANAGEMENT, INC.,              Defendant.  )  )  )  )  )  )  )  )  )  )  )  )  CASE NO. 0:19cv60205  STATUTORY VIOLATIONS OF THE TELEPHONE CONSUMER  PROTECTION ACT, 47 U.S.C. § 227 ET SEQ.  