13.  At all times relevant, Plaintiff was a citizen of the County of Alameda,  State of California.  Plaintiff is, and at all times mentioned herein was, a “person” as  defined by 47 U.S.C. § 153(39).   14.  Defendant is, and at all times mentioned herein was, a “person,” as  defined by 47 U.S.C. § 153(39).   15.  At all times relevant Defendant conducted business in the State of  California and in the County of Alameda, within this judicial district.   16.  In or about June 10, 2020, Plaintiff received an unsolicited text message  from Defendant on his cellular telephone, number ending in -6544.   23.  Plaintiff brings this action on behalf of himself and on behalf of and all  others similarly situated (“the Class”).   24.  Plaintiff represents, and is a member of, the Class, consisting of all  persons within the United States who received any unsolicited text messages from  Defendant which text message was not made for emergency purposes or with the  recipient’s prior express consent within the four years prior to the filing of this  Complaint.   25.  Defendant 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.   26.  Plaintiff and members of the Class were harmed by the acts of  Defendant in at least the following ways: Defendant, either directly or through their  agents, illegally contacted Plaintiff and the Class members via their cellular  telephones by using marketing and text messages, 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.   27.  This suit seeks only damages and injunctive relief for recovery of  economic injury on behalf of the Class, and it expressly is not intended to request  any recovery for personal injury and claims related thereto.  Plaintiff reserves the  right to expand the Class definition to seek recovery on behalf of additional persons  as warranted as facts are learned in further investigation and discovery.   35.  Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   36.  The foregoing acts and omissions of Defendant constitute numerous  and multiple negligent 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.   37.  As a result of Defendant’s negligent violations of 47 U.S.C. § 227 et  seq, Plaintiff and The Class are entitled to an award of $500.00 in statutory damages,  for each and every violation, pursuant to 47 U.S.C. § 227(b)(3)(B).   38.  Plaintiff and the Class are also entitled to and seek injunctive relief  prohibiting such conduct in the future.  NEGLIGENT VIOLATIONS OF THE TELEPHONE CONSUMER PROTECTION ACT  47 U.S.C. § 227 ET SEQ.   THE TCPA, 47 U.S.C. § 227 ET SEQ.   As a result of Defendant’s 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. 