10.  Defendant’s messages to constituted “telephone solicitation” as  defined by the TCPA, 47 U.S.C. § 227(a)(4) and “unsolicited advertisement” as  defined by the TCPA, 47 U.S.C. § 227(a)(5).   11.  Defendant used an “telephone facsimile machine” as defined by 47  U.S.C. § 227(a)(3) to place its calls to Plaintiff seeking to sell or solicit its business  services.   19.  Plaintiff brings this action on behalf of himself and all others similarly  situated, as a member of the two proposed classes (hereafter “The Classes”).   20.  The class concerning the unsolicited telephone facsimile messages  (hereafter “The Facsimile Class”) is defined as follows:  All persons within the United States who received any  telephone facsimile messages from Defendant to said  person’s telephone facsimile number made through the  use of any telephone facsimile machine and such person  had not previously consented to receiving such messages  within the four years prior to the filing of this Complaint   21.  The class concerning unsolicited text messages (hereafter “The  Texting Class”) is defined as follows:  All persons within the Unites States who received any   SMS messages from Defendant to said person’s cellular   telephone made through the use of any automatic   telephone dialing system or an artificial or prerecorded voice   and such person had not previously consented to receiving   such messages within the four years prior to the filing   of this Complaint   22.  Plaintiff represents, and is a member of, The Facsimile Class,  consisting of all persons within the United States who received any telephone  facsimile messages from Defendant to said person’s telephone facsimile number  made through the use of any telephone facsimile machine and such person had not  previously not provided their telephone facsimile number to Defendant within the  four years prior to the filing of this Complaint.   8.  Beginning in or around March 2017, Defendant contacted Plaintiff on  its cellular telephone number ending in -6147 and, beginning in or around February  2017, on it facsimile numbers ending in -2803, and -2428 as well in an effort to sell  or solicit its services.    9.  Defendant contacted Plaintiff via facsimile from telephone numbers  confirmed to belong to Defendant.    Knowing and/or Willful Violations of the Telephone Consumer Protection  Act   47 U.S.C. §227 et seq.   As a result of Defendant’s willful and/or knowing violations of 47  U.S.C. §227(b)(1), Plaintiff and the Class members are entitled to   and request treble damages, as provided by statute, up to $1,500, for  each and every violation, pursuant to 47 U.S.C. §227(b)(3)(B) and 47  U.S.C. §227(b)(3)(C); and    Any and all other relief that the Court deems just and proper.   Knowing and/or Willful Violations of the Telephone Consumer Protection Act   47 U.S.C. §227 et seq.   As a result of Defendant’s willful and/or knowing violations of 47  U.S.C. §227(b)(1), Plaintiff and the Class members are entitled to   and request treble damages, as provided by statute, up to $1,500, for  each and every violation, pursuant to 47 U.S.C. §227(b)(3)(B) and 47  U.S.C. §227(b)(3)(C); and    Any and all other relief that the Court deems just and proper.   Negligent Violations of the Telephone Consumer Protection Act  47 U.S.C. §227 et seq.   As a result of Defendant’s negligent violations of 47 U.S.C.  §227(b)(1), Plaintiff and the Class members are entitled to and  request $500 in statutory damages, for each and every violation,  pursuant to 47 U.S.C.  227(b)(3)(B); and   Any and all other relief that the Court deems just and proper.  