12.  Defendant Jornaya provides a variety of “real time” products for companies who  engage in telemarketing.     13.  Jornaya’s products include “TCPA Guardian” and “LeadiD,” which help businesses  evade the Telephone Consumer Protection Act (“TCPA”) by creating evidence of purported consent  to receive telemarketing calls, and to secretly collect data from website users for marketing  purposes.     14.  Jornaya’s products include a tool called “Visual Playback,” which surreptitiously  records, in real time, a website visitor’s keystrokes, mouse clicks, and other interactions on a  website.   15.  On its website, Jornaya says that its “real time” recording of user interactions begins  “the moment a customer lands on a webpage.” This technology allows Jornaya to “witness[]  [customers’] interactions and collect[] data related to their experience.”     32.  Plaintiff seeks to represent a class of all California residents who visited cars.com  and whose electronic communications were intercepted or recorded by Jornaya.  Plaintiff reserves  the right to modify the class definition as appropriate based on further investigation and discovery  obtained in the case.    33.  Members of the Class are so numerous that their individual joinder herein is  impracticable.  On information and belief, members of the Class number in the thousands.  The  precise number of Class members and their identities are unknown to Plaintiff at this time but may  be determined through discovery.  Class members may be notified of the pendency of this action by  mail and/or publication through the distribution records of Defendants.   34.  Common questions of law and fact exist as to all Class members and predominate  over questions affecting only individual Class members.  Common legal and factual questions  include, but are not limited to, whether Defendants have violated the California Invasion of Privacy  Act (“CIPA”), Cal. Penal Code § 631 and invaded Plaintiff’s privacy rights in violation of the  California Constitution; and whether class members are entitled to actual and/or statutory damages  for the aforementioned violations.     39.  Plaintiff repeats the allegations contained in the foregoing paragraphs as if fully set  forth herein.   40.  Plaintiff brings this claim individually and on behalf of the members of the proposed  Class against Defendants.   50.  Plaintiff repeats the allegations contained in the foregoing paragraphs as if fully set  forth herein.   51.  Plaintiff brings this claim individually and on behalf of the members of the proposed  Class against Defendants.   Violation Of The California Invasion Of Privacy Act,  Cal. Penal Code § 631   Violation Of The California Invasion Of Privacy Act,  Cal. Penal Code § 635  