10. In September 2014, Plaintiff purchased a medical device from  Defendant that requires him to periodically purchase supplies for its  continued use.    12. Defendant calls Plaintiff at least every three months and plays the  same prerecorded message each time. If plaintiff does not answer his phone,  or does not place an order with Defendant, Defendant calls every day with  the same message.   13. One of the numbers from which Defendant called Plaintiff was  identified as (651) 632-9800.    14. These calls made by Defendant were generated by an automatic  dialer, as evidenced by the fact that when these calls went to Plaintiff’s  voicemail, Defendant left a prerecorded voicemail message. Each of the  phone messages was identical in content and voice.   16. The length of the call is just over two-and-a-half minutes.   22. Plaintiff brings this action as a class action pursuant to Rule 23 of the  Federal Rules of Civil Procedure on behalf of a class (the “Class”) defined  as follows:   All persons in the United States and its  territories  who  received  one  or  more  unauthorized automated or pre-recorded phone  calls or voicemail messages from or on behalf of  Fairview Health Services or any of its  subsidiaries or affiliates.  Plaintiff reserves the right to redefine the Class or subclass prior to class  certification.    23. Numerosity: Members of the proposed Class are so numerous that  their individual joinder is impracticable. The precise number of members is  unknown to Plaintiff at this time. However, upon information and belief, it  is at least several thousand individuals. The true number of proposed  members is, however, known by Defendant, and thus, Class members may  be notified of the pendency of this action by first class mail, electronic, and  published notice using information in Defendant’s business and marketing  records.    25. Typicality: Plaintiff’s claims are typical of the other members of the  proposed Class because they received unauthorized phone calls and  voicemail messages from Defendant using an automatic telephone dialing  system.    27. Declaratory and Injunctive Relief: Defendant has acted or refused to  act on grounds generally applicable to Plaintiff and the other proposed Class  members, thereby making appropriate final injunctive relief and declaratory  relief, as described below, with respect to the Class as a whole.    28. Predominance: This case should be certified as a class action because  the common questions of law and fact concerning Defendant’s liability for  making unauthorized phone calls and leaving unauthorized voicemail  messages will predominate the litigation over any questions that may affect  individual Class members.   