10.  For some or all of the calls, UNIVERSAL used an auto-dialing mechanism  wherein there was no caller on the line when Plaintiff answered.  On only one occasion of a  phone call was a person available to speak to Plaintiff.    11.  These phone calls were, according to the callers, for marketing purposes or for  purposes of taking surveys of consumers to gather data.    12.  When one calls 646-467-6665, a prerecorded message says that the caller has  reached “Universal Survey Center, a marketing and political research company.”   13.  Plaintiff did not consent to these calls.   15.  Plaintiff and the class have been substantially damaged by Defendant’s calls.  Their privacy was improperly invaded, they were charged for the calls and they were annoyed.  Mims v. Arrow Financial Services, Inc., 132 S.Ct. 740 (Jan. 18, 2012) (discussing congressional  findings of consumer “outrage” as to autodialed and prerecorded calls); Soppet v. Enhanced  Recovery Co., LLC, 679 F.3d 637 (7th Cir. 2012) (stating that unwanted cell phone robocall  recipients are damaged because they are charged “out of pocket” cellular airtime minutes).     16.  Plaintiff’s cell phone plan is “pay by the minute.”   17.  Defendant’s violations were willful, or alternatively they were knowing;  particularly a call that occurred after Plaintiff asked that they stop and indicated that she was not  interested.   18.  Plaintiff incorporates all previous paragraphs.   19.  UNIVERSAL violated the TCPA by placing automated calls to Plaintiff and the  class members’ cell phones using its predictive dialer and/or prerecorded or artificial voice  without the consent of the called party.    20.  UNIVERSAL has a policy, practice or procedure of placing calls to cell phones  regarding the collection of an alleged debt without the prior consent of the called parties.   21.  UNIVERSAL’S violations were negligent, or alternatively, they were willful or  knowing. 47 U.S.C. §312(f)(1).  23.  The class is so numerous that joinder of all members is impractical.  Upon  information and belief Plaintiff alleges that there are more than 40 members of the class.   24.  There are questions of law and fact common to the class which predominate any  questions affecting an individual class member. The predominant common questions include:  a. Whether UNIVERSAL used an automatic telephone dialing system as is used  in the TCPA and applicable FCC regulations and orders to place the calls at  issue;   b. Damages, including whether the violations were negligent, willful or  knowing.     25.  Plaintiff will fairly and adequately protect the interests of the class.  Plaintiff has  retained counsel experienced in handling class actions and claims involving unlawful business  practices.  Neither Plaintiff nor Plaintiff's counsel have any interests which might cause them not  to vigorously pursue this action.    26.  A class action is an appropriate method for the fair and efficient adjudication of  this controversy.  The interest of class members in individually controlling the prosecution of  separate claims is small because it is not economically feasible to bring individual actions.    27.  Management of this class action is likely to present significantly fewer difficulties  than those presented in many class actions, e.g. for securities fraud.   29.  Defendant has acted on grounds generally applicable to the class, thereby making  relief appropriate with respect to the class as a whole.  Prosecution of separate actions by  individual members of the class, should they realize their rights have been violated, would likely  create the risk of inconsistent or varying adjudications with respect to individual members of the  class that would establish incompatible standards of conduct.   7.  UNIVERSAL has called Plaintiff’s cellular telephone numerous times within the  one year immediately preceding the filing of this complaint.    8.  For example, UNIVERSAL called Plaintiff’s cell phone on April 22, 2014 at 8:43  p.m., April 23, 2014 at 6:17 p.m., April 24, 2014 at 8:34 p.m., April 25, 2014 at 8:32 p.m., April  26, 2014 at 1:33 p.m., April 27, 2014 at 3:59 p.m., April 27, 2014 at 7:12 p.m., April 28, 2014 at  4:08 p.m., April 28, 2014 at 7:12 p.m., April 28, 2014 at 8:39 p.m., and May 1, 2014 at 6:46  p.m..   9.  The caller ID for these calls was 646-467-6665.   