11. At all times relevant, Plaintiff was a citizen of the State of California.  Plaintiff is, and at all times mentioned herein was, a “person” as defined by 47  27. Plaintiff brings this action on behalf of himself and on behalf of and all others  similarly situated (“the Class”).   39. Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.  40. The foregoing acts and omissions of Defendant constitute numerous and  multiple negligent violations of the TCPA, including but not limited to each  and every one of the above-cited provisions of 47 U.S.C. § 227 et seq.   41. As a result of Defendant’s negligent violations of 47 U.S.C. § 227 et news.,  Plaintiff and the Class are entitled to an award of $500.00 in statutory  damages, for each and every violation, pursuant to 47 U.S.C. §227(b)(3)(B).   42. Plaintiff and the Class are also entitled to and seek injunctive relief  prohibiting such conduct in the future.  47. As a result of Defendant’s negligent violations of 47 U.S.C. §227(b)(1),  Plaintiff seeks for herself and each Class member $500.00 in statutory  damages, for each and every violation, pursuant to 47 U.S.C. § 277(b)(3)(C).   48. Pursuant to 47 U.S.C. § 227(b)(3)(A), injunctive relief prohibiting such  conduct in the future.   49. Any other relief the Court may deem just and proper.  50. As a result of Defendant’s negligent violations of 47 U.S.C. §227(b)(1),  Plaintiff seeks for herself and each Class member $500.00 in statutory  damages, for each and every violation, pursuant to 47 U.S.C. § 277(b)(3)(C).   KNOWING AND/OR WILLFUL VIOLATIONS OF THE TELEPHONE  CONSUMER PROTECTION ACT  47 U.S.C. § 277 ET SEQ.  NEGLIGENT VIOLATIONS OF THE TELEPHONE CONSUMER  PROTECTION ACT 47 U.S.C. § 227 ET SEQ.  TCPA, 47 U.S.C. § 227 ET SEQ.  TCPA, 47 U.S.C. § 227 ET SEQ. 