10.  At all times relevant, Plaintiffs were citizens of the State of  California.  Plaintiffs are, and at all times mentioned herein were each, a “person”  as defined by 47 U.S.C. § 153 (10).   11.  Defendant is, and at all times mentioned herein was, a corporation  and a “person,” as defined by 47 U.S.C. § 153 (10).   12.  At all times relevant Defendant conducted business in the State of  California and in the County of San Diego, within this judicial district.   13.  Beginning in or around June of 2013, Defendant began to utilize  Plaintiffs’ cellular telephone number, ending in 0490, to place virtually daily  incessant calls to Plaintiffs pertaining to an alleged debt owed stemming from  medical services rendered in 2012.   14.  In during this time, Defendant placed calls on a daily basis, often  placing numerous calls a day.     15.  In July of 2013, Plaintiffs delivered a written correspondence to  Defendant, which amongst other things, made a written demand that any and all  telephone calls regarding the alleged debt must cease.    23.  Plaintiffs bring this action on behalf of themselves and on behalf of  and all others similarly situated (“the Class”).   35.  Plaintiffs incorporate by reference all of the above paragraphs of this  Complaint as though fully stated herein.   36.  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.   37.  As a result of Defendant’s negligent violations of 47 U.S.C. § 227 et  seq, Plaintiffs 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).   38.  Plaintiffs and the Class are also entitled to and seek injunctive relief  prohibiting such conduct in the future.  39.  Plaintiffs incorporate by reference all of the above paragraphs of this  Complaint as though fully stated herein.   43.  As a result of Defendant’s negligent violations of 47 U.S.C. §  227(b)(1), Plaintiffs seek for themselves and each Class member $500.00 in  statutory damages, for each and every violation, pursuant to 47 U.S.C. §  227(b)(3)(B).   44.  Pursuant to 47 U.S.C. § 227(b)(3)(A), injunctive relief prohibiting  such conduct in the future.   45.  Any other relief the Court may deem just and proper.  KNOWING AND/OR WILLFUL VIOLATIONS OF THE  TELEPHONE CONSUMER PROTECTION ACT  47 U.S.C. § 227 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.   VIOLATIONS OF THE TCPA, 47 U.S.C. § 227 ET SEQ.  