10. Defendant contacted or attempted to contact Plaintiff from telephone number 503-468-5336.   11. Defendant’s calls constituted calls that were not for emergency purposes as defined by 47 U.S.C. § 227(b)(1)(A).   12. During all relevant times, Defendant did not possess Plaintiff’s “prior express consent” to receive calls using an automatic telephone dialing system or an  artificial or prerecorded voice on his cellular telephone pursuant to 47 U.S.C. §  227(b)(1)(A).   13. Further, Plaintiff’s cellular telephone number ending in -7558 was added to the National Do-Not-Call Registry at least 30 days prior to receiving  Defendant’s calls.   14. Defendant placed multiple calls soliciting its business to Plaintiff on his cellular telephone ending in -7558 in or around April 2018.   15. Such calls constitute solicitation calls pursuant to 47 C.F.R. §  17. Plaintiff brings this action individually and on behalf of all others similarly situated, as a member the two proposed classes (hereafter, jointly, “The  Classes”). 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  telephone facsimile messages from Defendant to said  person’s telephone facsimile number made through the  use of any telephone facsimile machine and such person  had not previously consented to receiving such messages  and such messages did not contain any opt-out notice  within the four years prior to the filing of this Complaint   18. The class concerning the National Do-Not-Call violation (hereafter “The DNC Class”) is defined as follows:  All persons within the United States registered on the  National Do-Not-Call Registry for at least 30 days, who  had not granted Defendant prior express consent nor had  a prior established business relationship, who received  more than one call made by or on behalf of Defendant  that promoted Defendant’s products or services, within  any twelve-month period, within four years prior to the  filing of the complaint.   64.1200(c)(2) as they were attempts to promote or sell Defendant’s services.   8. Beginning in or around April 2018, Defendant contacted Plaintiff on Plaintiff’s cellular telephone number ending in -7558, 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.   Knowing and/or Willful Violations of the Telephone Consumer Protection Act  47 U.S.C. §227 (b)  • 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(c)  • As a result of Defendant’s negligent violations of 47 U.S.C. §227(c)(5), Plaintiff and the DNC Class members are entitled to and request $500 in statutory damages, for each and every violation,  pursuant to 47 U.S.C.  227(c)(5).   • Any and all other relief that the Court deems just and proper.