15.  North American Bancard is a payment processor provider for  businesses.    16.  However, North American Bancard’s contact with the potential new  customers is limited, and the telemarketing is conducted by third parties, such as  Integrated Payment Technologies.   17.  In fact, Integrated Payment Technologies’s website,  www.integratedpmt.com, redirects to a North American Bancard website.   18.  Defendants’ strategy for generating new customers involves the use of  an automatic telephone dialing system (“ATDS”) to solicit business.   19.  Recipients of these calls, including Plaintiff, did not consent to receive  them.  The Automated Telemarketing Call From Defendants    20.  Plaintiff is, and at all times mentioned herein was, a “person” as  defined by 47 U.S.C. § 153(39).   21.  Plaintiff’s telephone number, (818)-266-XXXX, is registered to a  cellular telephone service, which is the number he received the call on.   63.  Plaintiff and the proposed Dialer Class incorporate the foregoing  allegations as if fully set forth herein.   Violations of the TCPA, 47 U.S.C. § 227(b)  (On Behalf of Plaintiff and the Dialer Class)  