(On behalf of Plaintiff and the Class)   45.  Plaintiff incorporates by reference the foregoing allegations as if fully set forth herein.   46.  Defendant made unsolicited text message calls to cellular telephone numbers belonging to  Plaintiff and the other members of the Class en masse without their prior express consent.   48.  Defendant utilized equipment that made, or had made on their behalf, the text message  calls to Plaintiff and other members of the Class simultaneously and without human  intervention.   49.  By making, or having made on their behalf, the unsolicited text message calls to Plaintiff  and the Class, Defendant violated 47 U.S.C. § 227(b)(1)(A)(iii) and 47 U.S.C. §227(c)(5).  As a result of Defendant’s unlawful conduct, Plaintiff and the members of the Class  suffered actual damages in the form of money they paid to receive the unsolicited text  message calls on their cellular phones and are entitled to statutory damages under section  227(b)(3)(B) and 227(c)(5) at a minimum of $500.00 in damages for each such violation  of the TCPA.   50.  Should the Court determine that Defendants’ conduct was willful and knowing, the Court  may, pursuant to section 227(b)(3)(C), treble the amount of statutory damages recoverable  by Plaintiff and the other members of the Class. 