27.  Plaintiff brings this case as a class action pursuant to Fed. R. Civ. P. 23 on behalf  of himself and all others similarly situated.   28.  Plaintiff represents, and is a member of, the following two classes:  Class A   All persons within the United States to whom RAC or its agent/s and/or  employee/s called said person’s cellular telephone through the use of any  automatic telephone dialing system within the four years prior to the filing of  the Complaint where such person was not a customer of RAC.  Class B  All persons within the United States to whom RAC or its agent/s and/or  employee/s called said person’s cellular telephone with an artificial or  prerecorded voice within the four years prior to the filing of the Complaint  where such person was not a customer of RAC.   29.  Defendant and its employees or agents are excluded from the Classes. Plaintiff  does not know the number of members in the Classes, but believes the class members number in  the several thousands, if not more. Thus, this matter should be certified as a class action to assist  in the expeditious litigation of this matter.  B. Numerosity   30.  Upon information and belief, Defendant has placed automated and/or prerecorded  message calls to cellular telephone numbers belonging to thousands of consumers, without the  called party’s prior express consent, throughout the United States.  The members of the Classes,  therefore, are believed to be so numerous that joinder of all members is impracticable.   38.  Plaintiff repeats and realleges the above paragraphs of this Complaint and  incorporates them herein by reference.   39.  Defendant negligently placed multiple automated and prerecorded/artificial voice  calls to cellular numbers belonging to Plaintiff and the other members of the Classes without  their prior express consent.   40.  Each of the aforementioned calls by Defendant constitutes a negligent violation of  the TCPA.   44.  Plaintiff repeats and realleges the above paragraphs of this Complaint and  incorporates them herein by reference.   45.  Defendant knowingly and/or willfully placed multiple automated and  prerecorded/artificial voice calls to cellular numbers belonging to Plaintiff and the other  members of the Classes without their prior express consent.   46.  Each of the aforementioned calls by Defendant constitutes a knowing and/or  willful violation of the TCPA.   47.  As a result of Defendant’s knowing and/or willful violations of the TCPA,  Plaintiff and the Class are entitled to an award of treble damages up to $1,500.00 for each call in  violation of the TCPA pursuant to 47 U.S.C. § 227(b)(3)(B) and 47 U.S.C. § 227(b)(3)(C).   A. The Class   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.  