11.  On May 26, 2015, Defendant sent an unsolicited advertisement to  Plaintiff’s ink-and-paper facsimile machine.  The fax advertises “Be a Medical  Assistant Online.”  A copy of this facsimile is attached hereto and marked as  Exhibit A.     12.  Indeed, between July 13, 2015 and August 24, 2015, Defendant sent  at least 3 additional unsolicited faxes to Plaintiff’s ink-and-paper facsimile  machines.  See attached Exhibit B, a completion of 3 faxes sent to Plaintiff by  Defendant.  Upon information and belief, Plaintiff has received hundreds, if not  thousands, of additional fax advertisements from Defendant similar to Exhibit A.   13.  Defendant did not have Plaintiff’s prior express invitation or  permission to send advertisements to Plaintiff’s fax machine.   14.  Defendant’s faxes do not contain opt-out notices that comply with the  requirements of the TCPA.  16.  Plaintiff reserves the right to modify or amend the definition of the  proposed Class before the Court determines whether certification is proper, as  more information is gleaned in discovery.    17.  Excluded from the Class are Defendant, any parent, subsidiary,  affiliate, or controlled person of Defendant, as well as the officers, directors,  agents, servants, or employees of Defendant and the immediate family members of  any such person.  Also excluded are any judge who may preside over this case and  any attorneys representing Plaintiff or the Class.   18.  Numerosity [Fed R. Civ. P. 23(a)(1)].  The Members of the Class are  so numerous that joinder is impractical.  Upon information and belief, Defendant  has sent illegal fax advertisements to hundreds if not thousands of other recipients.   21.  Fair and Adequate Representation [Fed. R. Civ. P. 23(a)(4)].  Plaintiff  will fairly and adequately represent and protect the interests of the Class.  It is  interested in this matter, has no conflicts, and has retained experienced class  counsel to represent the Class.  