10.  Defendant contacted or attempted to contact Plaintiff from multiple  telephone numbers.   11.  Defendant’s calls constituted calls that were not for emergency  purposes as defined by 47 U.S.C. § 227(b)(1)(A).   12.  Defendant’s calls were placed to 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).    18.  Plaintiff brings this action individually and on behalf of all others  similarly situated, as a member the ATDS Class.   19.  The class concerning the ATDS claim for no prior express consent  (hereafter “The ATDS Class”) is defined as follows:  All persons within the United States who received any  solicitation/telemarketing  telephone  calls  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  calls within the four years prior to the filing of this  Complaint   8.  On or around December 2019, Defendant contacted Plaintiff on  Plaintiff’s cellular telephone number ending in -5400 in an attempt collect a debt.   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 collect a debt.    Knowing and/or Willful Violations of the Telephone Consumer Protection  Act   47 U.S.C. §227(b)  • As a result of Defendant’s willful and/or knowing violations of 47  U.S.C. §227(b)(1), Plaintiff and the ATDS 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).   • Any and all other relief that the Court deems just and proper.  