25.  Trump For President has devised and implemented a campaign marketing  strategy which includes the transmission of text message through use of automatic  telephone dialing systems.     26.  On October 1, 2019, Plaintiff Shell Wheeler received the following text  message to his cellular phone ending in the number 9457 from the number (855) 799- 8834: “Pres. Trump here. I want to see YOU Thursday, Oct. 10th at 7PM CDT at a  HISTORIC rally in Minneapolis, MN. To claim your free tickets, RSVP here!  bit.ly/2oewz2S.”     27.  When Plaintiff Wheeler clicked the hyperlink bit.ly/2oewz2S he was  directed to the Donald J. Trump campaign page, donaldJtrump.com.     28.  On October 3, 2019, Plaintiff Connor Olson received a similar text  message from the number (855) 821-0665 to his wireless number ending in 7141 stating  as follows:  “Pres. Trump: I want to see YOU Thursday, Oct. 10th at 7PM CDT at a  HISTORIC rally in Minneapolis, MN. To claim your free tickets, RSVP here!  bit.ly/2LI70k7.”     29.  When Plaintiff Olson clicked the hyperlink bit.ly/2LI70k7 he was directed  to the Donald J. Trump campaign page, donaldJtrump.com.     31.  Defendant did not obtain express consent from Plaintiffs prior to sending  the Plaintiffs the unsolicited text messages.     32.  Plaintiffs have no affiliation with the Trump For President campaign and  are registered Democrats who have never provided any donations to Donald J. Trump or  attended any previous campaign rally for Donald J. Trump.     33.  These unsolicited text messages placed to Plaintiffs’ wireless telephones  were placed via an “automatic telephone dialing system,” (“ATDS”) as defined by 47  U.S.C. § 227 (a)(1) and by using “an artificial or prerecorded voice” system as prohibited  by 47 U.S.C. § 227 (b)(1)(A), which had the capacity to produce or store numbers  randomly or sequentially, and to dial such numbers, to place text message calls to  Plaintiffs’ cellular telephones.   34.  The three ten-digit phone numbers that the text messages originated from  all resulted in an error message or disconnected dial tones when called.  This further  proves that the text messages did not originate from cellular phones but originated from  an ATDS.     36.  Furthermore, the text messages are prerecorded as prohibited by 47 U.S.C.  § 227 (b)(1)(A) as identical text messages were sent to numerous individuals.      37.  The identical nature of the text messages establishes that Defendant did not  manually dial or manually write the text messages that were sent to Plaintiffs.   38.  Plaintiffs are informed believe the spam political campaign text messages  they received were generated through communication technology called peer-to-peer  text messaging which is an ATDS that sends text messages to lists of cellular recipients  which have been uploaded by the Defendant.     39.  In addition to the October 16, 2019, text message received by Dan  Pederson, Mr. Pederson also received a text message on October 10, 2019 to his cellular  number ending in 1848 from the short code 88022.  The text message states as follows:  “Reply YES to join Trump and receive important messages.  No purchase rqd. Msg&data  may apply.  Terms apply 88022-info.com# jointed on donaldjtrump.com.     40.  At no point has Plaintiff Pederson ever voluntarily provided his 1848  number to Trump For President.     42.  The unsolicited text messages placed to Plaintiff Pederson wireless  telephone from the short code 88022 was placed via an “automatic telephone dialing  system,” (“ATDS”) as defined by 47 U.S.C. § 227 (a)(1) and by using “an artificial or  prerecorded voice” system as prohibited by 47 U.S.C. § 227 (b)(1)(A), which had the  capacity to produce or store numbers randomly or sequentially, and to dial such numbers,  to place text message calls to Plaintiff’s cellular telephone.   43.  Again, the existence of an ATDS is evidenced by the fact that the text  message received by Plaintiff Pederson from the number 88022 was generic as to the  intended recipient, i.e., the text messages did not address Plaintiff Pederson individually  or in any fashion. Such generic and impersonal messages indicate that these text  messages were sent in bulk fashion to numerous cellular telephones at one time and not  manually delivered by human intervention for each and every delivery.    44.   The telephone numbers that Defendant, or its agents, texted were assigned  to cellular telephone services for which Plaintiffs incurred a charge for incoming calls  pursuant to 47 U.S.C. § 227 (b)(1).   45.  These telephone calls constitute calls that were not for emergency purposes  as defined by 47 U.S.C. § 227(b)(1)(A)(i).   46.  Thus, these text messages by Defendant or its agents therefore violated 47  U.S.C. § 227(b)(1).  48.  Defendant and its employees or agents are excluded from the Class.   49.  Plaintiffs do not know the number of members in the Classes, but believe the  members number in the hundreds of thousands, if not more. Thus, this matter should be  certified as a class action to assist in the expeditious litigation of this matter.   51.  This suit seeks only damages and injunctive relief for recovery of  economic injury on behalf of the Classes and it expressly is not intended to request any  recovery for personal injury and claims related thereto. Plaintiffs reserve the right to  expand the definitions of the Classes to seek recovery on behalf of additional persons as  warranted as facts are learned in further investigation and discovery   52.  The joinder of the members of the Classes is impractical and the  disposition of their claims in the class action will provide substantial benefits both to the  parties and to the Court. The Classes can be identified through Defendant’s records or  Defendant’s agents’ records.   54.  As persons that received at least one text message to their cell phone  without their prior express consent, Plaintiffs are asserting claims that are typical of the  Classes. Plaintiffs will fairly and adequately represent and protect the interests of the  Class in that Plaintiffs have no interest antagonistic to any member of the Classes.   56.  Plaintiffs have retained counsel experienced in handling class action claims  and claims involving violations of the Telephone Consumer Protection Act.   57.  A class action is a superior method for the fair and efficient adjudication of  this controversy. Class-wide damages are essential to induce Defendant to comply with  federal law. The interest of the members of the Class in individually controlling the  prosecution of separate claims against Defendant is small because the maximum  statutory damages in an individual action for violation of privacy are minimal.  Management of these claims is likely to present significantly fewer difficulties than those  presented in many class claims.   58.  This class action is appropriate for certification because Defendant has  acted or refused to act on grounds generally applicable to the Class as a whole, thereby  requiring the Court’s imposition of uniform relief to ensure compatible standards of  conduct toward the members of the Class and making final injunctive relief appropriate  with respect to the Class as a whole. Defendant practices challenged herein apply to and  affect each of the Class’ members uniformly. Plaintiffs challenge to those practices  hinges on Defendant’s conduct with respect to the Class as whole, not on facts or law  applicable only to Plaintiffs.  60.  Each such text message was made using equipment that, upon information  and belief, had the capacity to store or produce telephone numbers to be called, using a  random or sequential number generator, and to dial such numbers. By using such  equipment, Defendant was able to effectively send thousands of text messages  simultaneously to lists of thousands of wireless phone numbers of consumers without  human intervention.   61.  These text messages are analogous to a prerecorded voice made without  the prior express consent of Plaintiffs.    62.  Defendant’s text messages were sent without the prior express consent of  the Plaintiffs and the other members of the Class to receive such text messages.   63.  The foregoing acts and omissions of Defendant and its agents constitute  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.   64.  As a result of Defendant’s, and Defendant’s agents’, negligent violations  of 47 U.S.C. § 227 et seq., Plaintiffs and the Class are entitled to an award of $500.00 in  statutory damages, for each and every violation, pursuant to 47 U.S.C.  § 227(b)(3)(B).   66.  Plaintiffs incorporate by reference all of the above paragraphs of this  Complaint as though fully stated herein.    67.  Each such text message was made using equipment that, upon information  and belief, had the capacity to store or produce telephone numbers to be called, using a  random or sequential number generator, and to dial such numbers. By using such  equipment, Defendant was able to effectively send thousands of text messages  simultaneously to lists of thousands of wireless phone numbers of consumers without  human intervention.   68.  These text messages are analogous to a prerecorded voice made without  the prior express consent of Plaintiffs.    69.  Defendant’s text messages were sent without the prior express consent of  the Plaintiffs and the other members of the Class to receive such text messages.   70.  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.   72.  Plaintiffs and the Classes are also entitled to and seek injunctive relief  prohibiting such conduct in the future.  73.  As a result of Defendant’s, and Defendant’s agents’, negligent violations  of 47 U.S.C. § 227(b)(1), Plaintiffs seek for themselves and each members of the Class  $500.00 in statutory damages, for each and every violation, pursuant to 47 U.S.C. §  227(b)(3)(B).   74.  Pursuant to 47 U.S.C. § 227(b)(3)(A), Plaintiffs seek injunctive relief  prohibiting such conduct in the future.   76.  As a result of Defendant’s, and Defendant’s agents’, willful and/or  knowing violations of 47 U.S.C. § 227(b)(1), Plaintiffs seek for themselves and each Class  member treble damages, as provided by statute, up to $1,500.00 for each and every  violation, pursuant to 47 U.S.C. § 227(b)(3)(B) and 47 U.S.C. § 227(b)(3)(C).   77.  Pursuant to 47 U.S.C. § 227(b)(3)(A), injunctive relief prohibiting such  conduct in the future.   78.  Any other relief the Court may deem just and proper.  KNOWING AND/OR WILLFUL VIOLATIONS OF THE  TELEPHONE CONSUMER PROTECTION ACT  47 U.S.C. §§ 227 ET SEQ.   NEGLIGENT VIOLATIONS OF THE TELEPHONE CONSUMER  PROTECTION ACT 47 U.S.C. §§ 227 ET SEQ.   VIOLATION OF THE TCPA, 47 U.S.C. §§ 227 ET SEQ.   WILLFUL VIOLATION OF THE TCPA, 47 U.S.C. §§ 227  ET SEQ.  