23.  On February 8, 2010, Plaintiff Valdes registered his cellular phone  number on the DNC to avoid receiving unsolicited phone calls.  Since that time,  the cellular phone number has been primarily for personal use.  Plaintiff has never  held the cellular phone number out to the public in connection with a business.   41.  Plaintiff repeats and realleges paragraphs 1 through 40 of this  Complaint and incorporates them by reference.   42.  Defendant’s realtors made unwanted solicitation calls to cellular  telephone numbers belonging to Plaintiff and the other members of the Autodialed  No Consent Class using equipment that, upon information and belief, had the  capacity to store or produce telephone numbers to be called, using a random or  sequential number generator.    43.  These solicitation telephone calls were made en masse without the  prior express written consent of Plaintiff and the other members of the Autodialed  No Consent Class.   44.  Defendant’s realtors made these calls negligently or willfully and  knowingly.   45.  Defendant is vicariously liable for its realtors’ calls because it  directed, apparently authorized, and/or ratified the realtors’ actions.   47.  Plaintiff repeats and realleges paragraphs 1 through 40 of this  Complaint and incorporates them by reference.   48.  The TCPA’s implementing regulations provide that “[n]o person or  entity shall initiate any telephone solicitation” to “[a] residential telephone  subscriber who has registered his or her telephone number on the national do-not- call registry of persons who do not wish to receive telephone solicitations that is  maintained by the federal government.”  47 C.F.R. § 64.1200(c).   49.  This regulation is “applicable to any person or entity making  telephone solicitations or telemarketing calls to wireless telephone numbers.” 47  C.F.R. § 64.1200(e).   56.  Plaintiff repeats and realleges paragraphs 1 through 40 of this  Complaint and incorporates them by reference.   Class Treatment Is Appropriate for Plaintiff’s TCPA Claims   Harcourts Prime Directs Realtors to Cold Call Consumers   Harcourts Prime’s Realtors Made Unsolicited, Autodialed Cold Calls to  Plaintiff   Telephone Consumer Protection Act  (Violations of 47 U.S.C. § 227)  (On Behalf of Plaintiff and the Internal Do Not Call Class)   Telephone Consumer Protection Act  (Violation of 47 U.S.C. § 227)  (On Behalf of Plaintiff Valdes and the Do Not Call Registry Class)   Telephone Consumer Protection Act  (Violation of 47 U.S.C. § 227)  (On Behalf of Plaintiff and the Autodialed No Consent Class)  