27.  Defendant owns and operates a medical marijuana licensing service, focusing on same- day provision of marijuana licenses to consumers seeking to take advantage of Defendant’s services.   39.  Plaintiff brings this action on behalf of two (2) nationwide classes of similarly situated  individuals.   40.  The first class is the “No Consent to Text Class,” of which is defined as:   [1] All persons in the United States [2] within the four years  immediately preceding the filing of this Complaint [3] whose cellular  telephone number [4] was sent one or more text message [5] marketing,  advertising, and/or otherwise promoting goods, services, or events [6]  from Defendant, or another person or entity acting on Defendant’s  behalf, [7] by and through an automatic telephone dialing system or  equipment [8] and Defendant lacked the class member’s express written  consent to send such text message(s).   41.  Plaintiff is a member of the No Consent to Text Class.   54.  Plaintiff re-alleges and incorporates paragraphs 1-53 as if fully set forth herein.   55.  It is a violation of the TCPA, 47 U.S.C. §227(b) to call a person's cellular telephone  using an automatic telephone dialing system. The TCPA also specifically prohibits the use of an  unsolicited text messages to advertise the sale of goods and services. 47 U.S.C. § 227(b)(1)(B); 47  59.  Plaintiff re-alleges and incorporates paragraphs 1-49 as if fully set forth herein.    60.  It is a violation of the TCPA, 47 U.S.C. §227(c) to call a person who has registered his  or her telephone number on the national do-not-call registry of persons who do not wish to receive  telephone solicitations. 47 U.S.C. § 227(c); 47 C.F.R. § 64.1200.   61.  Defendant, or some person on its behalf, sent one or more marketing text messages to  Plaintiff and others’ cellular telephone numbers when said numbers had been registered on the  national do-not-call registry for more than 31 days.   VIOLATION OF 47 U.S.C. § 227(c)   (THE DNC CLASS)   VIOLATION OF 47 U.S.C. § 227(b)   (THE NO CONSENT TO TEXT CLASS)  