10.  Defendant used an “automatic telephone dialing system,” as defined  by 47 U.S.C. § 227(a)(1), to place its calls to Plaintiff seeking to sell or solicit its  business services.    11.  Defendant’s calls constituted calls that were not for emergency  purposes as defined by 47 U.S.C. § 227(b)(1)(A).   12.  Defendant’s calls were placed to telephone number assigned to a  cellular telephone service for which Plaintiff incurs a charge for incoming calls  pursuant to 47 U.S.C. § 227(b)(1).    14.  Plaintiff brings this action on behalf of herself and all others similarly  situated, as a member of the proposed class (hereafter “The Class”) defined as  follows:  All persons within the United States who received any  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   15.  Plaintiff represents, and is a member of, The Class, consisting of All  persons within the United States who received any 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 not provided their cellular telephone number to Defendant within the  four years prior to the filing of this Complaint.   16.  Defendant, its employees and 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 thousands, if not more.  Thus, this matter should be  certified as a Class Action to assist in the expeditious litigation of the matter.   33.  Pursuant to the Seventh Amendment to the Constitution of the United  States of America, Plaintiff is entitled to, and demands, a trial by jury.  Respectfully Submitted this 4th day of January, 2017.  8.  Beginning in or around October 2015, Defendant contacted Plaintiff  on her cellular telephone ending in -7333, in an effort to sell or solicit its services.   Plaintiff advised Defendant several times to correspond in writing and cease the  calls, but Defendant continued to contact Plaintiff on her cellular telephone.   9.  Defendant called from the phone number (855) 306-9681.   Knowing and/or Willful Violations of the Telephone Consumer Protection Act   47 U.S.C. §227 et seq.   As a result of Defendant’s willful and/or knowing violations of 47  U.S.C. §227(b)(1), Plaintiff and the Class members are entitled to   and request treble damages, as provided by statute, up to $1,500, for  each and every violation, pursuant to 47 U.S.C. §227(b)(3)(B) and 47  U.S.C. §227(b)(3)(C); and    Any and all other relief that the Court deems just and proper.    Negligent Violations of the Telephone Consumer Protection Act  47 U.S.C. §227 et seq.   As a result of Defendant’s negligent violations of 47 U.S.C.  §227(b)(1), Plaintiff and the 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); and   Any and all other relief that the Court deems just and proper.  