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).    13.  Plaintiff is not a customer of Defendant’s services and has never  provided any personal information, including his cellular telephone number, to  Defendant for any purpose whatsoever.     16.  Plaintiff brings this action individually and on behalf of all others  similarly situated, as a member the proposed class (hereafter, “The Class”) 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   17.  Plaintiff represents, and is a member of, The Class, consisting of all  persons within the United States who received any solicitation 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.   18.  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.   8.  Beginning on or around May 6,  2019, Defendant contacted Plaintiff  on his cellular telephone ending in -6535, in an effort to sell or solicit its services.    9.  Defendant called Plaintiff on his cellular telephone from the following  phone number confirmed to belong to Defendant, (619) 720-3886.   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.  