19.  Defendants are “person[s]” as the term is defined by 47 U.S.C.  § 153(39).   20.  The Plaintiff’s phone number ending in 1901, has been on the  National Do Not Call List since prior to January 1, 2020.   21.  The number has a Virginia area code.   22.  The number is used by the Plaintiff for personal purposes.   23.  The number is not associated with a business.   25.  Indeed, the Plaintiff has previously filed suit against King’s Creek for  making telemarketing calls to him without his permission.   26.  Despite this, the Plaintiff has repeatedly received calls from Spinnaker  promoting its King’s Creek vacation property.   27.  On October 4, 2021, Plaintiff received a call from 757-553-3963.   28.  The caller identification information for the call did not include the  named of the telephone solicitor, and the 3963 number, when called back, did not  permit, during regular business hours, the Plaintiff to make a request not to receive  telephone solicitations.   29.  Prior to the caller joining the call there was a delay and a bloop sound  which is indicative of the use of calling software that makes automated calls and  then queues answered calls for available agents.   30.  The caller failed to identify himself or on whose behalf he was  calling.   31.  Ultimately, the caller promoted a time share presentation “under the  name of Spinnakers” at “191 Cottage Cove Lane, Williamsburg”.   33.  The next day on October 5, 2021, Plaintiff received another call from  “David” from the same number, again promoting a Spinnaker time share  presentation at the King’s Creek property.   34.  Other consumers have complained about the same types of unsolicited  calls regarding the King’s Creek property:  Kings Creek Plantation (Realty) practices unethical marketing. They  are spamming my phone constantly and I cannot stop them or contact  a human being I get 6 or more calls a day, EVERY DAY, from Kings  Creeks (Realty (Plantation/Timeshare). I have blocked the numbers  but they just go to my voicemail and load it up. Despite "Do Not Call"  lists and blocking from my phone, I still cannot stop these idiots. I  think that these people are extremely unethical. I know your office  knows about this timeshare business because the complaints on line  about this company are ubiquitous. I tried to contact this company by  phone without calling their "reserve an appointment" phone number to  no avail. I am retired and Williamsburg is less than an hour away by  car. We use to visit Williamsburg quite often but we have not lately  simply because of the bad vibes this company is providing your city..  That is because this creepy, high-pressure sales/spamming business is  sucking all the good feelings about Williamsburg right out of us.  Please, do something about it.  https://www.bbb.org/us/va/williamsburg/profile/timeshare-companies/kings- creek-resorts-llc-0583-51000709/complaints (last visited Nov. 2, 2021).   36.  Plaintiff and all members of the Classes, defined below, have been  harmed by the acts of Defendant because their privacy has been violated and they  were annoyed and harassed.  Plaintiff and the Class Members were also harmed by  use of their telephone power and network bandwidth and the intrusion on their  telephone that occupied it from receiving legitimate communications.  39.  Plaintiff brings all claims in this action individually and on behalf of  Class Members against Defendants.  Numerosity   40.  Members of the Classes are so numerous that their individual joinder is  impracticable.   41.  On information and belief, based on the technology used to call  Plaintiff, which is used to make calls en masse, Members of the Classes number in  the thousands.    42.  The precise number of Class Members and their identities are unknown  to Plaintiff at this time but may be determined through discovery.   43.  Class Members may be notified of the pendency of this action by mail  and/or publication through the distribution records of Defendants.  Commonality   44.  Common questions of law and fact exist as to all Class Members and  predominate over questions affecting only individual Class Members.    46.  The claims of the named Plaintiff are typical of the claims of the Class  because the named Plaintiff, like all other Class Members, received unsolicited  telephonic sales calls from the Defendants without giving them his consent to receive  such calls.  Adequacy of Representation   47.  Plaintiff is an adequate representative of the Class because his interests  do not conflict with the interests of the Class Members he seeks to represent, he has  retained competent counsel experienced in prosecuting class actions, and he intends  to prosecute this action vigorously.    48.  The interests of Class Members will be fairly and adequately protected  by Plaintiff and his counsel.  Superiority   49.  The class mechanism is superior to other available means for the fair  and efficient adjudication of the claims of Class Members.    50.  Many of the Class Members likely lack the ability and/or resources to  undertake the burden and expense of individually prosecuting what may be a  complex and extensive action to establish Defendant’s liability.     52.  Individualized litigation also presents a potential for inconsistent or  contradictory judgments.    53.  In contrast, the class action device presents far fewer management  difficulties and provides the benefits of single adjudication, economy of scale, and  comprehensive supervision by a single court on the issue of Defendant’s liability.     54.  Class treatment of the liability issues will ensure that all claims and  claimants are before this Court for consistent adjudication of the liability issues.  55.  Plaintiff repeats and incorporates the allegations set forth in paragraphs  1 through 53 as if fully set forth herein.   56.  Plaintiff brings this claim individually and on behalf of the Florida  Telephone Solicitation Act Autodial Class Members against Defendants.    58.  A “telephonic sales call” is defined as a “telephone call, text message,  or voicemail transmission to a consumer for the purpose of soliciting a sale of any  consumer goods or services, soliciting an extension of credit for consumer goods or  services, or obtaining information that will or may be used for the direct solicitation  of a sale of consumer goods or services or an extension of credit for such purposes.”  Fla. Stat. § 501.059(1)(i).   59.  Defendants failed to secure prior express written consent from Plaintiff  and the Class Members.   59.1-513.   60.  In violation of the FTSA, Defendants made and/or knowingly allowed  telephonic sales calls to be made to Plaintiff and the Class members without  Plaintiff’s and the Class members’ prior express written consent.   61.  Defendants made and/or knowingly allowed the telephonic sales calls  to Plaintiff and the Class members to be made utilizing an automated system for the  selection or dialing of telephone numbers.   63.  Plaintiff repeats and incorporates the allegations set forth in  paragraphs 1 through 53 as if fully set forth herein.   64.  The foregoing acts and omissions of Defendants and/or their affiliates,  agents, and/or other persons or entities acting on Defendants’ behalf constitute  numerous and multiple violations of the TCPA, 47 U.S.C. § 227, by making  telemarketing calls, except for emergency purposes, to the Plaintiff and the Class  despite their numbers being on the National Do Not Call Registry.   65.  The Defendants’ violations were negligent, willful, or knowing.   66.  As a result of Defendants’ and/or its affiliates, agents, and/or other  persons or entities acting on Defendants’ behalf violations of the TCPA, 47 U.S.C.  § 227, Plaintiff and members of the Class presumptively are entitled to an award  of between $500 and $1,500 in damages for each and every call made.   68.  Plaintiff repeats and incorporates the allegations set forth in paragraphs  1 through 53 as if fully set forth herein.   69.  Plaintiff brings this claim individually and on behalf of the Virginia  Telephone Privacy Protection Act National Do Not Call Registry Class Members  against Defendants.    70.  It is a violation of the VTPPA to “initiate, or cause to be initiated, a  telephone solicitation call to a telephone number on the National Do Not Call  Registry ….” Va. Stat. § 59.1-514(B).   71.  A “telephone solicitation call” is a call made “for the purpose of  offering or advertising any property, goods, or services for sale, lease, license, or  investment ….” Id at § 59.1-510.   72.  Defendants failed to secure prior express written consent from Plaintiff  and the Class Members.   74.  As a result of Defendants’ conduct, and pursuant to § 59.1-515 of the  VTPPA, Plaintiff and Class members were harmed and are each entitled to a  minimum of $500.00 in damages for each violation. Plaintiff and the Class members  are also entitled to an injunction against future calls. Id.  75.  Plaintiff repeats and incorporates the allegations set forth in paragraphs  1 through 53 as if fully set forth herein.   76.  Plaintiff brings this claim individually and on behalf of the Virginia  Telephone Privacy Protection Act Failure to Identify Class Members against  Defendants.    77.  It is a violation of the VTPPA to make or have made a telephonic sales  call during which the caller fails to promptly identify themselves by first and last  names and/or fails to promptly identify on whose behalf the telephone solicitation is  being made. Va. Stat. § 59.1-512.   79.  Defendants failed to secure prior express written consent from Plaintiff  and the Class Members.   80.  In violation of the VTPPA, Defendants made and/or knowingly allowed  telephonic sales calls to be made to Plaintiff and the Class members without  Plaintiff’s and the Class members’ prior express written consent even though during  the calls the caller failed to promptly identify themselves by first and last names  and/or failed to promptly identify the Defendants as the persons on whose behalf the  telephone solicitations were being made.   81.  As a result of Defendants’ conduct, and pursuant to § 59.1-515 of the  VTPPA, Plaintiff and Class members were harmed and are each entitled to a  minimum of $500.00 in damages for each violation. Plaintiff and the Class members  are also entitled to an injunction against future calls. Id.  82.  Plaintiff repeats and incorporates the allegations set forth in paragraphs  1 through 53 as if fully set forth herein.   84.  It is a violation of the VTPPA to make or have made telephone  solicitation calls that do not include the transmission of the name of the caller and/or  from numbers that do not permit, if called back during regular business hours, an  individual to make a request not to receive telephone solicitation calls. Va. Stat. §   85.  A “telephone solicitation call” is a call made “for the purpose of  offering or advertising any property, goods, or services for sale, lease, license, or  investment ….” Id at § 59.1-510.   86.  Defendants failed to secure prior express written consent from Plaintiff  and the Class Members.   87.  In violation of the VTPPA, Defendants made and/or knowingly allowed  telephonic sales calls to be made to Plaintiff and the Class members without  Plaintiff’s and the Class members’ prior express written consent even though the  calls did not include the transmission of the name of the caller and/or were made  from numbers that did not permit, if called back during regular business hours, an  individual to make a request not to receive telephone solicitation calls.   Telephone Consumer Protection Act  (Violations of 47 U.S.C. § 227)  (On Behalf of Plaintiff and the National Do Not Call Registry Class)   Violation of the Virginia Telephone Privacy Protection Act,   Va. Stat. § 59.1-513  On Behalf of Plaintiff and the Virginia Telephone Privacy Protection   Act Caller Identification Class   Violation of the Virginia Telephone Privacy Protection Act,   Va. Stat. § 59.1-514  On Behalf of Plaintiff and the Virginia Telephone Privacy Protection   Act National Do Not Registry Call Class   Violation of the Virginia Telephone Privacy Protection Act,   Va. Stat. § 59.1-512  On Behalf of Plaintiff and the Virginia Telephone Privacy Protection   Act Failure to Identify Call Class   Violation of the Florida Telephone Solicitation Act,   Fla. Stat. § 501.059  On Behalf of Plaintiff and the Florida Telephone Solicitation Act Autodial  Class  