17.  DRS placed approximately fifteen calls to Plaintiff’s cellular telephone number  between December 2018 and October 2019.   18.  In each of these telephone calls, DRS delivered an artificial or pre-recorded message  seeking to speak to a “Wilma Williams” regarding an alleged debt.   19.  In at least one of these artificial or pre-recorded messages, DRS requested that the  called party call (678) 940-1318 or visit the website www.directrecoveryservices.com to submit a  payment.   20.  In early Spring 2019, after receiving several telephone calls from DRS, Plaintiff  called DRS and left a voice message instructing DRS that it was calling a wrong number.   21.  Shortly after leaving that voice message, Plaintiff placed a call to DRS and spoke to a  live representative of DRS.   22.  In that conversation, Plaintiff again instructed DRS that it was calling a wrong  number, and instructed DRS to stop calling his telephone number.   23.  Despite acknowledging that instruction, DRS continued to place telephone calls to  Plaintiff’s cellular telephone number.   24.  After Plaintiff received yet another telephone call from DRS, Plaintiff responded to  that call by following an IVR prompt to speak to an agent, and again spoke to a live representative of  49.  Plaintiff brings this action as a class action under Federal Rule of Civil Procedure 23  on behalf of himself and the classes of similarly situated individuals as defined below:  TCPA class: All persons and entities throughout the United States (1) to  whom Direct Recovery Services, LLC, placed, or caused to be placed, calls  (2) directed to a number assigned to a cellular telephone service, (3) by using  an automatic telephone dialing system or an artificial or prerecorded voice,  (4) within the four years preceding the date of this complaint, (5) absent prior  express consent—in that the called party was not the intended recipient.   FDCPA class: All persons throughout the United States (1) to whom Direct  Recovery Services, LLC, placed, or caused to be placed, calls, (2) within the  one year preceding the date of this complaint, (3) and in connection with the  collection of a consumer debt, (4) where the person called Direct Recovery  Services, LLC was not the person alleged to owe the debt.   51.  Upon information and belief, the members of the classes are so numerous that joinder  of all of them is impracticable.    52.  The exact number of the members of the classes is unknown to Plaintiff at this time,  and can be ascertained only through appropriate discovery.    53.  The members of the classes are ascertainable because the classes are defined by  reference to objective criteria.    54.  In addition, the classes are ascertainable because, upon information and belief,  cellular telephone numbers, names, and addresses of the members of the classes can be identified in  business records maintained by Defendants and by third parties.    55.   There exists a well-defined community of interest in the questions of law and fact  that affect the members of the classes.    56.  Plaintiff’s claims are typical of the claims of the members of the classes.    57.  As it did for all members of the classes, DRS used an automatic telephone dialing  system, or an artificial or prerecorded voice, to place calls to Plaintiff’s cellular telephone number,  without prior express consent, and in violation of 47 U.S.C. § 227.    58.  And, as was the case for all members of the classes, Gusman directed and authorized  DRS to use an automatic telephone dialing system, or an artificial or prerecorded voice, to place  calls to Plaintiff’s cellular telephone number, without prior express consent, and in violation of 47  79.  Plaintiff repeats and re-alleges each and every factual allegation contained in  paragraphs 1-78.   81.   DRS violated 47 U.S.C. § 227(b)(1)(A)(iii) by utilizing an automatic telephone  dialing system to place calls to Plaintiff’s cellular telephone number without prior consent.    82.  DRS additionally and separately violated 47 U.S.C. § 227(b)(1)(A)(iii) by utilizing an  artificial or prerecorded voice when it delivered messages to Plaintiff’s cellular telephone number  without prior consent.    83.  Gusman is vicariously liable for DRS’s violations of 47 U.S.C. § 227(b)(1)(A)(iii)  because, on information and belief, she authorized DRS’s conduct of using an automatic telephone  dialing system to place telephone calls to Plaintiff’s cellular telephone number without prior consent.   84.  As a result of Defendants’ violations of 47 U.S.C. § 227(b)(1)(A)(iii), Plaintiff, and  the members of the classes, are entitled to damages in an amount to be proven at trial.  85.  Plaintiff repeats and re-alleges each and every factual allegation contained in  paragraphs 1-78.   86.  Defendants caused Plaintiff’s cellular telephone to ring repeatedly or continuously,  with intent to annoy, abuse, or harass him, even after he informed Defendants that they were calling  the wrong number.   88.  Plaintiff repeats and re-alleges each and every factual allegation contained in  paragraphs 1-78.  