10.  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.    11.  Defendant contacted or attempted to contact Plaintiff from telephone  number (602) 483-1403, which Plaintiff alleges on information and belief was a  spoofed telephone number, indicating Defendant’s attempts to mask its identity to  avoid accountability from placing illegal robocalls, as well as having used an  ATDS to place the calls.   21.  Plaintiff brings this action individually and on behalf of all others  similarly situated, as a member the two proposed classes (hereafter, jointly, “The  Classes”).    9.  Beginning in or around October 2019, Defendant contacted Plaintiff  on Plaintiff’s cellular telephone number ending in -6678, in an attempt to solicit  Plaintiff to purchase Defendant’s 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 ATDS 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).   • 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. 