29.  Plaintiffs bring this action on behalf of themselves and all others  similarly situated (“the Class”).   30.  Plaintiffs represent, and are members of, the Class, defined as follows:  All persons within the United States who received any  solicitation/telemarketing telephone calls and/or text  messages from Defendants 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 calls within the four years prior to the  filing of this Complaint   31.  Defendants and their employees or agents are excluded from the Class.   Plaintiffs do not know the number of members in the Class but believe the Class  members number in the hundreds of thousands, if not more.  Thus, this matter  should be certified as a Class action to assist in the expeditious litigation of this  matter.   Negligent Violations of the Telephone Consumer Protection Act  47 U.S.C. §227(b)  • As a result of Defendant’s negligent violations of 47 U.S.C.  §227(b)(1), Plaintiffs 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).   • Any and all other relief that the Court deems just and proper. 