11.  Get Together, Inc. created an app called IRL which is designed to  allow consumers to interact with friends and relatives within the app and to plan  events and get-togethers.   12.  Defendant Scott Banister is the co-founder of the IRL app3 4 which was  designed to use ‘growth hacking’ to collect contact information from a consumer’s  phone and to send that list of contacts automated text messages without their  consent.   13.  Get Together, Inc. was formerly the GatherApp, Inc.5    14.  The Gather App was created, advertised, and implemented much like  the IRL app.   15.  The Gather App was banned by Apple and other app stores for their  abusive spam telemarketing techniques and privacy invasions.    16.  In addition, the Gather App was sued in four different lawsuits for  violations of the TCPA in 2017, much like the IRL app today over their unsolicited  text messages similar to the ones in this complaint.   37.  Plaintiff’s cell phone number has been registered on the Do Not Call  registry since October 1, 2005.   38.  On March 27, 2018 at 9:22 AM, Plaintiff received a text message from  Defendant on his cellular telephone using phone number 844-607-3607 stating,  “Hi! Someone you know complimented you – You can use IRL to vote on your  friends, find out who voted on you, and make plans – irl.co/dl/ [hands-up emoji]  Reply INFO for info, STOP to unsubscribe”.   58.  Plaintiff repeats and realleges paragraphs 1 through 57 of this  Complaint and incorporates them by reference.   59.  Defendants sent autodialed text messages to cellular telephone  numbers belonging to Plaintiff and other members of the Autodialed No Consent  Class without first obtaining prior consent to send such autodialed text messages.   63.  Plaintiff repeats and realleges paragraphs 1 through 57 of this  Complaint and incorporates them by reference.   68.  Plaintiff repeats and realleges paragraphs 1 through 57 of this  Complaint and incorporates them by reference.   Telephone Consumer Protection Act  (Violation of 47 U.S.C. § 227)  (On Behalf of Plaintiffs and the Do Not Call Registry Class)   Telephone Consumer Protection Act  (Violations of 47 U.S.C. § 227)  (On Behalf of Plaintiff and the Internal Do Not Call Class)   Telephone Consumer Protection Act  (Violation of 47 U.S.C. § 227)  (On Behalf of Plaintiff the Autodialed No Consent Class)   