(Knowing and/or Willful Violations of the Telephone Consumer Protection  Act, 47 U.S.C. § 227(b)(1)(A))   (Violations of the Telephone Consumer Protection Act, 47 U.S.C. §  227(b)(1)(A))   12.  United Card Solutions offers various payment technologies for  businesses. About United Card Solutions, United Card Solutions,  http://unitedcardsolutions.com (last visited Feb. 15, 2018).   13.  One of United Card Solutions’s strategies for marketing its payment  services and generating new customers is telemarketing.   14.  United Card’s strategy for generating new customers involved the use  of an automatic telephone dialing system (“ATDS”) to solicit business.   15.  United Card uses ATDS equipment that has the capacity to store or  produce telephone numbers to be called, that includes autodialers and predictive  dialers and that plays a prerecorded message once the calls connect.   16.  Recipients of these calls, including Plaintiff, did not consent to receive  such telephone calls.   17.  Plaintiff is, and at all times mentioned herein was, a “person” as  defined by 47 U.S.C. § 153(39).   18.  Plaintiff’s telephone number, “(818)-700-XXXX,” is registered to a  cellular telephone service.   19.  On October 2, 2017, Plaintiff received a pre-recorded call from the  Defendant.   39.  Plaintiff realleges and incorporates by reference each and every  allegation set forth in the preceding paragraphs.   40.  The foregoing acts and omissions of United Card Solutions and/or its  affiliates or agents, and/or other persons or entities acting on United Card  Solutions’s behalf, constitute numerous and multiple violations of the TCPA, 47  U.S.C. § 227(b)(1)(A), by making non-emergency calls to the cellular telephone  numbers of Plaintiff and members of the Class using an ATDS and/or artificial or  prerecorded voice.   41.  As a result of violations of the TCPA, 47 U.S.C. § 227(b)(1)(A), by  United Card Solutions and/or its affiliates or agents and/or other persons or entities  acting on its behalf, Plaintiff and members of the Class are entitled to an award of  $500 in damages for each and every call made to their cellular telephone numbers  using an ATDS and/or artificial or prerecorded voice in violation of the statute,  pursuant to 47 U.S.C. § 227(b)(3)(B).   42.  Plaintiff and members of the Class are also entitled to and do seek  injunctive relief prohibiting United Card Solutions, its affiliates and agents, and/or  any other persons or entities acting on its behalf from violating the TCPA, 47  U.S.C. § 227(b)(1)(A), by making calls, except for emergency purposes, to any  cellular telephone numbers using an ATDS and/or artificial or prerecorded voice. 