10. At all times relevant, Plaintiff was a citizen of the State of California.   Plaintiff is, and at all times mentioned herein was, a “person” as defined by  47 U.S.C. § 153 (10).   11. Defendant is, and at all times mentioned herein was, a corporation and a  “person,” as defined by 47 U.S.C. § 153 (10).   12. At all times relevant Defendant conducted business in the State of California  and in the County of San Diego, within this judicial district.   13. At no time did Plaintiff ever enter into a business relationship with  Defendants.   14. Plaintiff did not provide Plaintiff’s cellular telephone numbers to Defendant  through any medium at any time.   24. Plaintiff brings this action on behalf of herself and on behalf of and all  others similarly situated (“the Class”).   36. Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   37. The foregoing acts and omissions of Defendant constitutes numerous and  multiple negligent violations of the TCPA, including but not limited to each  and every one of the above-cited provisions of 47 U.S.C. § 227 et seq.   38. As a result of Defendant’s negligent violations of 47 U.S.C. § 227 et seq,  Plaintiff and The Class are entitled to an award of $500.00 in statutory  damages, for each and every violation, pursuant to 47 U.S.C. § 227(b)(3)(B).   39. Plaintiff and the Class are also entitled to and seek injunctive relief  prohibiting such conduct in the future.  KNOWING AND/OR WILLFUL VIOLATIONS OF THE  TELEPHONE CONSUMER PROTECTION ACT  47 U.S.C. § 227 ET SEQ.   NEGLIGENT VIOLATIONS OF THE TELEPHONE CONSUMER PROTECTION  ACT  47 U.S.C. § 227 ET SEQ.   THE TCPA, 47 U.S.C. § 227 ET SEQ.  • As a result of Defendant’s negligent violations of 47 U.S.C. § 227(b)(1),  Plaintiff seeks for herself and each Class member $500.00 in statutory  damages, for each and every violation, pursuant to 47 U.S.C. §  227(b)(3)(B).  • Pursuant to 47 U.S.C. § 227(b)(3)(A), injunctive relief prohibiting such  conduct in the future.  • Any other relief the Court may deem just and proper. 