38.  All Web Leads generated the “leads” by placing telemarketing robocalls to  consumers to see if they might be interested in purchasing insurance, and then transferring those  calls to the Defendants.   39.  On behalf of Defendants and at their direction, All Web Leads made hundreds of  thousands of autodialed telemarketing calls to Plaintiffs and class members without their prior  express consent to inquire whether Plaintiffs and the Class were interested in purchasing insurance.   40.  Defendants, through All Web Leads, orchestrated a mass unlawful telemarketing  campaign to Plaintiffs and the Class through the use of a single, uniform website— www.affordable-health-insurance-plans.org. (the “Affordable Health Care Website”)— that all of  the Plaintiffs and Class Members visited for purposes of obtaining health insurance quotes online.     41.  What’s more, the Affordable Health Care Website was deceptively designed to  appear, similarly to the government-run “Healthcare.gov” marketplace website, as though it would  generate health insurance quotes online.     42.  After Plaintiffs and the Class visited the Affordable Health Care Website,  Defendants, through their agent All Web Leads, placed autodialed telemarketing calls to their  cellular phones for the purpose of selling insurance without their prior express written consent in  violation of the TCPA.  Calls to Plaintiffs   44.  Plaintiff Cooper visited the Affordable Health Care Website in search of health  insurance quotes online.     45.  After Plaintiff Cooper visited the website, she received an autodialed telemarketing  call placed by All Web Leads on behalf of Defendant CS Marketing on January 2, 2018 at or  around 10:14 a.m.       46.  Upon answering the call, there was an immediate pause on the other end, followed  by a distinct “clicking” noise before the connection with a representative was made.     47.  The All Web Leads representative asked Plaintiff Cooper a series of questions to  determine whether she met certain criteria specified by Defendant CS Marketing in order to find  out if she was a qualified consumer to whom Defendant could sell insurance.   48.  After the series of questions concluded, Plaintiff Cooper was then transferred to a  health insurance sales representative for Defendant CS Marketing.     49.  During that call, Defendant CS Marketing proceeded to solicit Plaintiff Cooper to  purchase insurance.     51.  To compound matters, on information and belief, Plaintiff Cooper received  numerous other autodialed telemarketing calls to her cell phone as a result of becoming entangled  in Defendants’ unlawful telemarketing scheme.    Calls to Plaintiff Rodriguez   52.  Plaintiff Rodriguez visited the Affordable Health Care Website in search of health  insurance quotes online.     53.  After Plaintiff Rodriguez visited the website, he received multiple autodialed  telemarketing calls placed by All Web Leads on behalf of Defendant Health Insurance Innovations  on January 3, 2018 at 8:33 a.m. and then again at 1:49 p.m.       54.  Upon answering the call, there was an immediate pause on the other end, followed  by a distinct “clicking” noise before the connection with a representative was made.     55.  The All Web Leads representative asked Plaintiff Rodriguez a series of questions  to determine whether he met certain criteria specified by Defendant Health Insurance Innovations  in order to find out if he was a qualified consumer to whom it could sell insurance.   56.  After the series of questions concluded, Plaintiff Rodriguez was then transferred to  a health insurance sales representative for Defendant Health Insurance Innovations.     57.  During that call, Defendant Health Insurance Innovations proceeded to solicit  Plaintiff Rodriguez to purchase insurance.     59.  To compound matters, on information and belief, Plaintiff Rodriguez received  numerous other autodialed telemarketing calls to his cell phone as a result of becoming entangled  in Defendants’ unlawful telemarketing scheme.    Calls to Plaintiff Niegsch   60.  Plaintiff  Niegsch visited the Affordable Health Care Website in search of health insurance quotes  online.     61.  After Plaintiff Niegsch visited the website, she received an autodialed  telemarketing call placed by All Web Leads on behalf of Defendant Health Insurance Innovations  on March 14, 2016 at 3:52 p.m.       62.  Upon answering the call, there was an immediate pause on the other end, followed  by a distinct “clicking” noise before the connection with a representative was made.     63.  The All Web Leads representative asked Plaintiff Niegsch a series of questions to  determine whether she met certain criteria specified by Defendant Health Insurance Innovations  in order to find out if she was a qualified consumer to whom it could sell insurance.   64.  After the series of questions concluded, Plaintiff Niegsch was then transferred to a  health insurance sales representative for Defendant Health Insurance Innovations.     65.  During that call, Defendant Health Insurance Innovations proceeded to solicit  Plaintiff Niegsch to purchase insurance.     67.  To compound matters, on information and belief, Plaintiff Niegsch received  numerous other autodialed telemarketing calls to her cell phone as a result of becoming entangled  in Defendants’ unlawful telemarketing scheme.    Calls to Plaintiff Cortes   68.  Plaintiff Cortes visited the Affordable Health Care Website in search of health  insurance quotes online.     69.  After Plaintiff Cortes visited the website, he received an autodialed telemarketing  call placed by All Web Leads on behalf of Defendant Insurance Care Direct on May 5, 2018 at  7:36 a.m.       70.  Upon answering the call, there was an immediate pause on the other end, followed  by a distinct “clicking” noise before the connection with a representative was made.     71.  The All Web Leads representative asked Plaintiff Cortes a series of questions to  determine whether he met certain criteria specified by Defendant Insurance Care Direct in order  to find out if he was a qualified consumer to whom it could sell insurance.   72.  After the series of questions concluded, Plaintiff Cortes was then transferred to a  health insurance sales representative for Defendant Insurance Care Direct.     73.  During that call, Defendant Insurance Care Direct proceeded to solicit Plaintiff  Cortes to purchase insurance.     75.  To compound matters, on information and belief, Plaintiff Cortes received  numerous other autodialed telemarketing calls to his cell phone as a result of becoming entangled  in Defendants’ unlawful telemarketing scheme.  Calls to Plaintiff Moss   76.  Plaintiff Moss visited the Affordable Health Care Website in search of health insurance quotes  online.     77.  After Plaintiff Moss visited the website, he received multiple autodialed  telemarketing calls placed by All Web Leads on behalf of Defendant Insurance Care Direct on  May 24, 2018 at 2:10 p.m. and then again at 2:31 p.m.       78.  Upon answering the call, there was an immediate pause on the other end, followed  by a distinct “clicking” noise before the connection with a representative was made.     79.  The All Web Leads representative asked Plaintiff Moss a series of questions to  determine whether he met certain criteria specified by Defendant Insurance Care Direct in order  to find out if he was a qualified consumer to whom it could sell insurance.   80.  After the series of questions concluded, Plaintiff Moss was then transferred to a  health insurance sales representative for Defendant Insurance Care Direct.     81.  During that call, Defendant Insurance Care Direct proceeded to solicit Plaintiff  Moss to purchase insurance.     83.  To compound matters, on information and belief, Plaintiff Moss received numerous  other autodialed telemarketing calls to his cell phone as a result of becoming entangled in  Defendants’ unlawful telemarketing scheme.  Calls to Plaintiff Williams   84.  Plaintiff Williams visited the Affordable Health Care Website in search of health  insurance quotes online.     85.  After Plaintiff Williams visited the website, he received an autodialed  telemarketing call placed by All Web Leads on behalf of Defendant MBS on December 14, 2015  at 12:43 p.m.       86.  Upon answering the call, there was an immediate pause on the other end, followed  by a distinct “clicking” noise before the connection with a representative was made.     87.  The All Web Leads representative asked Plaintiff Williams a series of questions to  determine whether het met certain criteria specified by Defendant MBS in order to find out if he  was a qualified consumer to whom it could sell insurance.   88.  After the series of questions concluded, Plaintiff Williams was then transferred to  a health insurance sales representative for Defendant MBS.     89.  During that call, Defendant MBS proceeded to solicit Plaintiff Williams to purchase  insurance.     91.  To compound matters, on information and belief, Plaintiff Williams received  numerous other autodialed telemarketing calls to his cell phone as a result of becoming entangled  in Defendant’s unlawful telemarketing scheme.  Calls to Plaintiff Barnes   92.  Plaintiff Barnes visited the Affordable Health Care Website in search of health  insurance quotes online.     93.  After Plaintiff Barnes visited the website, she received an autodialed telemarketing  call placed by All Web Leads on behalf of Defendant MHP Insurance on December 29, 2017 at  1:27 p.m.       94.  Upon answering the call, there was an immediate pause on the other end, followed  by a distinct “clicking” noise before the connection with a representative was made.     95.  The All Web Leads representative asked Plaintiff Barnes a series of questions to  determine whether she met certain criteria specified by Defendant MHP Insurance in order to find  out if she was a qualified consumer to whom it could sell insurance.   96.  After the series of questions concluded, Plaintiff Barnes was then transferred to a  health insurance sales representative for Defendant MHP Insurance.     97.  During that call, Defendant MHP Insurance proceeded to solicit Plaintiff Barnes to  purchase insurance.     Defendants Engaged in a Concerted, Uniform and   Unlawful Telemarketing Campaign Through Their Agent All Web Leads   