10.  Defendant’s calls constituted communications that were not for  emergency purposes as defined by 47 U.S.C. § 227(b)(1)(A).   11.  Defendant’s calls were placed to a telephone number assigned to a  cellular telephone service for which Plaintiff incurs a charge for incoming calls  pursuant to 47 U.S.C. § 227(b)(1).    12.  Plaintiff is not a customer of Defendant’s services and has never  provided any personal information, including his cellular telephone number, to  Defendant for any purpose whatsoever.  Accordingly, Defendant never received  Plaintiff’s “prior express consent” to receive calls using an automatic telephone  dialing system or an artificial or prerecorded voice on his cellular telephone  pursuant to 47 U.S.C. § 227(b)(1)(A).    8.  Beginning on or around July 18, 2019, Defendant called Plaintiff on  his cellular telephone, ending in -7919, in an effort to sell or solicit its services.   9.  Defendant used an “automatic telephone dialing system”, as defined  by 47 U.S.C. § 227(a)(1) to place its calls to Plaintiff seeking to sell or solicit its  business services.  At one or more instance during these communications,  Defendant utilized an “artificial or prerecorded voice” as prohibited by 47 U.S.C.  § 227(b)(1)(A).   INC; DOES 1 through 10, inclusive,  Defendant.  )  )  )  )  )  )  )  )  )  )  )  )  )  )  )  Case No.   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.   Respectfully Submitted this 18th day of December, 2020. 