10.  Defendant’s message constituted “telephone solicitation” as defined  by the TCPA, 47 U.S.C. § 227(a)(4) and “unsolicited advertisement” as defined by  the TCPA, 47 U.S.C. § 227(a)(5).   11.  Defendant used a “telephone facsimile machine” as defined by 47  U.S.C. § 227(a)(3) to place its message to Plaintiff seeking to sell or solicit its  business services.    12.  Defendant’s message constituted message that were not for  emergency purposes as defined by 47 U.S.C. § 227(b)(1)(A).   15.  Plaintiff brings this action on behalf of himself and all others similarly  situated, as a member of the proposed class (hereafter “The Class”) defined as  follows:  All persons within the United States who received any  telephone facsimile messages from Defendant to said  person’s telephone facsimile number made through the  use of any telephone facsimile machine and such person  had not previously consented to receiving such messages    16.  Plaintiff represents, and is a member of, The Class, consisting of All  persons within the United States who received any telephone facsimile messages  from Defendant to said person’s telephone facsimile number made through the use  of any telephone facsimile machine and such person had not previously provided  their telephone facsimile number to Defendant within the four years prior to the  filing of this Complaint.   17.  Defendant, its employees and agents are excluded from The Class.   Plaintiff does not know the number of members in The Class, but believes the Class  members number in the thousands, if not more. Thus, this matter should be certified  as a Class Action to assist in the expeditious litigation of the matter.   8.  Beginning in or around March of 2019, Defendant contacted Plaintiff  on his telephone facsimile numbers ending in -4206, in an effort to sell or solicit its  services.    9.  Defendant contacted Plaintiff via facsimile from telephone numbers  confirmed to belong to Defendant.   Negligent Violations of the Telephone Consumer Protection Act  47 U.S.C. §227 et seq.  • As a result of Defendant’s negligent violations of 47 U.S.C.  §227(b)(1), Plaintiff and the Class members are entitled to and  request $500 in statutory damages, for each and every violation,  pursuant to 47 U.S.C.  227(b)(3)(B); and  • Any and all other relief that the Court deems just and proper.  