23.  Plaintiff incorporates by reference the foregoing paragraphs of this Class  Action Complaint as though fully stated herein.   24.  Plaintiff is, and at all times mentioned herein was, the subscriber of the  cellular telephone number (720) ***-9071 (the “9071 Number”).  The 9071 Number  is, and at all times mentioned herein was, assigned to a cellular telephone service as  specified in 47 U.S.C. § 227(b)(1)(A)(iii).     42.  Plaintiff brings this class action on behalf of herself individually and on  behalf of all other similarly situated persons pursuant to Federal Rule of Civil  Procedure 23 (the “Class”).  The Class which Plaintiff is a member of and seeks to  represent is comprised of and defined as follows:  All persons within the United States to whom, within four (4)  years prior to the filing of this action, one or more text  message(s) promoting Defendants’ goods or services was  sent by Defendants or an affiliate, subsidiary, or agent of  Defendants, utilizing an automatic telephone dialing system,  without prior express written consent to be sent such text  message(s).   43.  Defendants, their employees, and agents are excluded from the Class.   44.  Plaintiff reserves the right to modify or expand the definition of the  Class (or add one or more subclasses) as warranted as facts are learned or confirmed  after further investigation and discovery.   58.  Plaintiff incorporates by reference the foregoing paragraphs of this Class  Action Complaint as if fully stated herein.   63.  Plaintiff incorporates by reference the foregoing paragraphs of this Class  Action Complaint as if fully stated herein.   64.  The foregoing acts and omissions constitute numerous and multiple  knowing and/or willful violations of the TCPA by Defendants, including but not  limited to violations of each and every one of the above-cited provisions of 47 U.S.C.  §§ 227, et seq.   65.  As a result of Defendants’ violations of the TCPA, Plaintiff and the  Class members are entitled to, and do seek, injunctive relief prohibiting such conduct  violating the TCPA in the future pursuant to 47 U.S.C. § 227(b)(3)(A).   66.  As a result of Defendants’ knowing and/or willful violations of the  TCPA, Plaintiff the Class members are also entitled to, and do seek, an award of  treble damages as provided by statute, of $1,500.00 in statutory damages for each  violation of the TCPA pursuant to 47 U.S.C. § 227(b)(3)(B) and § 227(b)(3)(C).   KNOWING AND/OR WILLFUL VIOLATIONS OF THE TCPA  47 U.S.C. §§ 227, ET SEQ.   NEGLIGENT VIOLATIONS OF THE TCPA  47 U.S.C. §§ 227, ET SEQ.  