10.  At all times relevant, Plaintiff was domiciled in and a citizen of the State of  California.  Plaintiff is, and at all times mentioned herein was, a “person” as defined by 47  26.  Plaintiff brings this action on behalf of himself and on behalf of all others  similarly situated (“the Class”).   27.  Plaintiff represents, and is a member of the Class, consisting of:  All persons within the United States who received any telephone call/s  from Defendants or their agent/s and/or employee/s to said person’s  cellular telephone made through the use of any automatic telephone  dialing system within the four years prior to the filing of the Complaint.   28.  Defendants and their 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 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.   29.  Plaintiff and members of the Class were harmed by the acts of Defendants in at  least the following ways:  Defendants, either directly or through its agents, illegally contacted  Plaintiff and the Class members via their cellular telephones by using an ATDS, thereby causing  Plaintiff and the Class members to incur certain cellular telephone charges or reduce cellular  telephone time for which Plaintiff and the Class members previously paid, and invading the  privacy of said Plaintiff and the Class members.  Plaintiff and the Class members were damaged  thereby.   42.  Plaintiff incorporates by reference all of the above paragraphs of this Complaint  as though fully stated herein.   43.  The foregoing acts and omissions of Defendants constitute 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.   44.  As a result of Defendants knowing and/or willful violations of 47 U.S.C. § 227 et  seq., Plaintiff and The Class are entitled to an award of $1,500.00 in statutory damages, for each  and every violation, pursuant to 47 U.S.C. § 227(b)(3)(B) and 47 U.S.C. § 227(b)(3)(C).   I, Alex Madar, hereby certify that, according to the computer program used to prepare  this document, Complaint, contains 3820 words.  I declare under penalty of perjury under the laws of the State of California that the  foregoing is true and correct.  Executed on this 5th day of August, 2019, in San Diego, California.    /s/ Alex S. Madar  Alex S. Madar  Attorney for Plaintiff  KNOWING AND/OR WILLFUL VIOLATIONS OF THE  TELEPHONE CONSUMER PROTECTION ACT (TCPA)  47 U.S.C. 227   THE (TCPA), 47 U.S.C. 227 ET. SEQ.  �   As a result of Defendants negligent violations of 47 U.S.C. § 227(b)(1), Plaintiff seeks  for himself and each Class member $500.00 in statutory damages, for each and every  violation, pursuant to 47 U.S.C. § 227(b)(3)(B).  �  Pursuant to 47 U.S.C. § 227(b)(3)(A), injunctive relief prohibiting such conduct in the  future.  �  Any other relief the Court may deem just and proper. 