19.  At various times in 2014, Plaintiff placed an ad on the Miami/Dade Craigslist in  an attempt to sell a motor vehicle. Plaintiff listed his cellular telephone number 786-XXX-0174  as a contact number.   20.  Plaintiff’s Craigslist ads, without exception, stated “do NOT contact me with  unsolicited services or offers.” More specifically, the text of the Craigslist ads stated, “Please  don’t text me,” or “please be serious before calling.”   21.  At some point thereafter, Defendant ICO, using some type of Lead Generating  software and in complete disregard of Plaintiff’s instructions, “scraped” Plaintiff’s cellular  telephone number from one or more of Plaintiff’s Craigslist ads and sent the following text  message to Plaintiff’s cellular telephone twice:  “We are cash buyers for local vehicles. Get a cash offer 24/7 -  http://bit.ly/p9z972L – Off Lease Only Miami”   23.  Both of the aforementioned text messages were received on Plaintiff’s cellular  telephone within a 12-month period, and within the time frame relevant to this complaint.   24.  Upon information and belief, the text message was sent using an automatic  telephone dialing system within the meaning of 47 U.S.C. § 227(a)(1).   25.  At no point in time did Plaintiff provide Defendants with his express written  consent to be contacted on his cellular telephone using automatic telephone dialing equipment.    26.  Defendants’ violations of the TCPA were knowing and willful. ICO intentionally  “scraped” cellular telephone numbers from Craigslist ads, with the intent to send mass text  messages to the scraped numbers, without first obtaining the requisite consent to do so.   27.  Moreover, Plaintiff’s telephone number is listed on the national Do Not Call  Registry3 since 2008, reinforcing the proposition that Defendants knew or should have known  not to call Plaintiff for the purpose of marketing their services, but did so anyway.   28.  Plaintiff brings this case as a class action pursuant to Fed. R. Civ. P. 23, on behalf  of himself and all others similarly situated.    30.  Defendants and its employees or agents are excluded from the Class.  Plaintiff  does not know the number of members in the Class, but believes the Class members number in  the several thousands, if not more.   Numerosity   32.  The exact number and identities of the Class members are unknown at this time  and can only be ascertained through discovery. Identification of the Class members is a matter  capable of ministerial determination from Defendants’ call records.  Common Questions of Law and Fact   33.  There are numerous questions of law and fact common to the Class which  predominate over any questions affecting only individual members of the Class. Among the  questions of law and fact common to the Class are:  a. Whether Defendants made non-emergency calls to Plaintiff’s and Class members’  cellular telephones using an autodialer and/or prerecorded message;  b. Whether Defendants can meet its burden of showing that they obtained prior  express consent to make such calls;  c. Whether Defendants’ conduct was knowing and willful;  d. Whether Defendants are liable for damages, and the amount of such damages; and  e. Whether Defendants should be enjoined from such conduct in the future.    34.  The common questions in this case are capable of having common answers. If  Plaintiff’s claim that Defendants routinely places automated calls, prerecorded calls, and/or text  messages to telephone numbers assigned to cellular telephone services is accurate, Plaintiff and  the Class members will have identical claims capable of being efficiently adjudicated and  administered in this case.  Typicality   36.  Plaintiff is a representative who will fully and adequately assert and protect the  interests of the Class, and has retained counsel who is experienced in prosecuting class actions.  Accordingly, Plaintiff is an adequate representative and will fairly and adequately protect the  interests of the Class.  Proceeding Via Class Action is Superior and Advisable   37.  A class action is superior to all other available methods for the fair and efficient  adjudication of this lawsuit, because individual litigation of the claims of all members of the  Class is economically unfeasible and procedurally impracticable.  While the aggregate damages  sustained by the Class are in the millions of dollars, the individual damages incurred by each  member of the Class resulting from Defendant’s wrongful conduct are too small to warrant the  expense of individual lawsuits. The likelihood of individual Class members prosecuting their  own separate claims is remote, and, even if every member of the Class could afford individual  litigation, the court system would be unduly burdened by individual litigation of such cases.   38.  The prosecution of separate actions by members of the Class would create a risk  of establishing inconsistent rulings and/or incompatible standards of conduct for Defendants.   For example, one court might enjoin Defendants from performing the challenged acts, whereas  another may not.  Additionally, individual actions may be dispositive of the interests of the  Class, although certain class members are not parties to such actions.  39.  Plaintiff realleges and incorporates the preceding paragraphs of this Complaint as  if fully set forth herein.   40.  ICO placed multiple automated calls, prerecorded calls, and/or text messages to  cellular numbers belonging to Plaintiff and the other members of the Class without their prior  express consent.   41.  Each of the aforementioned calls and text messages by ICO constitute a violation  of the TCPA.   42.  As a result of ICO’s violations of the TCPA, Plaintiff and the Class are entitled to  an award of $500.00 in statutory damages for each call in violation of the TCPA pursuant to 47  U.S.C. § 227(b)(3)(B).   43.  Additionally, Plaintiff and the Class are entitled to and seek injunctive relief  prohibiting such future conduct by ICO.   WHEREFORE, Plaintiff and members of the Class demand a jury trial on all claims so  triable, and judgment against Defendant seeking the following:   a.  Injunctive relief prohibiting violations of the TCPA by Defendants in the future;  b.  Statutory damages of $500.00 for each and every call made in violation of the  TCPA pursuant to 47 U.S.C. § (b)(3)(B); and  c.  Such other relief as this Court deems just and proper.   45.  ICO knowingly and willfully placed multiple automated calls, prerecorded calls,  and/or text messages to cellular numbers belonging to Plaintiff and the other members of the  Class without their prior express consent.   46.  Each of the aforementioned calls by ICO constitute a knowing and willful  violation of the TCPA.   47.  As a result of ICO’s knowing and willful violations of the TCPA, Plaintiff and the  Class are entitled to an award of treble damages up to $1,500.00 for each call in violation of the  TCPA pursuant to 47 U.S.C. § 227(b)(3)(B) and 47 U.S.C. § 227(b)(3)(C).   48.  Additionally, Plaintiff and the Class are entitled to and seek injunctive relief  prohibiting such future conduct by ICO.  WHEREFORE, Plaintiff and members of the Class demand a jury trial on all claims so  triable, and judgment against Defendant seeking the following:   a.  Injunctive relief prohibiting violations of the TCPA by Defendants in the future;  b.  Statutory damages of $1500.00 for each and every call made in violation of the  TCPA pursuant to 47 U.S.C. § (b)(3)(B); and  c.  Such other relief as this Court deems just and proper.   49.  Plaintiff realleges and incorporates the preceding paragraphs of this Complaint as  if fully set forth herein.   50.  Plaintiff and the other members of the Class received more than one telephone  call within any 12-month period, by or on behalf of the same entity, without their prior express  consent and to which they object.   52.  As a result of ICO’s violations of the TCPA, Plaintiff and the Class are entitled to  an award of up to $1,500.00 for each call in violation of the TCPA pursuant to 47 U.S.C. §  227(c)(5).   53.  Additionally, Plaintiff and the Class are entitled to and seek injunctive relief  prohibiting such future conduct by ICO.  WHEREFORE, Plaintiff and members of the Class demand a jury trial on all claims so  triable, and judgment against Defendant seeking the following:   a.  Injunctive relief prohibiting violations of the TCPA by Defendants in the future;  b.  Statutory damages of $1500.00 for each and every call made in violation of the  TCPA pursuant to 47 U.S.C. § (b)(3)(B); and  c.  Such other relief as this Court deems just and proper.   54.  Plaintiff realleges and incorporates the preceding paragraphs of this Complaint as  if fully set forth herein.   55.  OLO, through its agent, ICO, placed multiple automated calls, prerecorded calls,  and/or text messages to cellular numbers belonging to Plaintiff and the other members of the  Class without their prior express consent.   56.  Each of the aforementioned calls by OLO constitute a violation of the TCPA.   57.  As a result of OLO’s violations of the TCPA, Plaintiff and the Class are entitled  to an award of $500.00 in statutory damages for each call in violation of the TCPA pursuant to  47 U.S.C. § 227(b)(3)(B).   59.  Plaintiff realleges and incorporates the preceding paragraphs of this Complaint as  if fully set forth herein.   60.  OLO, through its agent, ICO, knowingly and willfully placed multiple automated  calls, prerecorded calls, and/or text messages to cellular numbers belonging to Plaintiff and the  other members of the Class without their prior express consent.   61.  Each of the aforementioned calls by OLO constitute a knowing and willful  violation of the TCPA.   62.  As a result of OLO’s knowing and willful violations of the TCPA, Plaintiff and  the Class are entitled to an award of treble damages up to $1,500.00 for each call in violation of  the TCPA pursuant to 47 U.S.C. § 227(b)(3)(B) and 47 U.S.C. § 227(b)(3)(C).   64.  Plaintiff realleges and incorporates the preceding paragraphs of this Complaint as  if fully set forth herein.   65.  Plaintiff and the other members of the Class received more than one telephone  call within any 12-month period, by or on behalf of the same entity, without their prior express  consent and to which they object.   66.  The telephone numbers to which the unwanted calls were made were listed on the  national Do No Call Registry.   67.  As a result of OLO’s violations of the TCPA, Plaintiff and the Class are entitled  to an award of up to $1,500.00 for each call in violation of the TCPA pursuant to 47 U.S.C. §  227(c)(5).   ICO’S WILLFUL OR KNOWING VIOLATION OF 47 U.S.C. § 227(b)(1)(a)(iii)   ICO’s VIOLATION OF 47 U.S.C. § 227(c)   OLO’s VIOLATION OF 47 U.S.C. § 227(c)   OLO’S WILLFUL OR KNOWING VIOLATION OF 47 U.S.C. § 227(b)(1)(a)(iii)   OLO’S VIOLATION OF 47 U.S.C. § 227(b)(1)(a)(iii)   The Proposed Classes  