10.  Defendant contacted or attempted to contact Plaintiff from multiple  telephone numbers.    15.  Plaintiff brings this action individually and on behalf of all others  similarly situated, as a member the proposed class (hereafter, jointly, “The Class”).    16.  The class concerning the ATDS claim for no prior express consent  (hereafter “The ATDS Class”) is defined as follows:  All persons within the United States who received any  solicitation/telemarketing  telephone  calls  from  Defendant to said person’s cellular telephone made  through the use of any automatic telephone dialing  system or an artificial or prerecorded voice and such  person had not previously consented to receiving such  calls within the four years prior to the filing of this  Complaint   8.  Beginning in or around March 2019, Defendant contacted Plaintiff on  Plaintiff’s cellular telephone number ending in -6443, in an attempt to solicit  Plaintiff to purchase Defendant’s services.     9.  Defendant used an “automatic telephone dialing system” as defined  by 47 U.S.C. § 227(a)(1) to place its call to Plaintiff seeking to solicit its services.    Negligent Violations of the Telephone Consumer Protection Act  47 U.S.C. §227(b)  • As a result of Defendant’s negligent violations of 47 U.S.C.  §227(b)(1), Plaintiff and the ATDS Class members are entitled to and  request $500 in statutory damages, for each and every violation,  pursuant to 47 U.S.C.  227(b)(3)(B).   • Any and all other relief that the Court deems just and proper. 