22.  Plaintiff brings this action pursuant to Federal Rule of Civil Procedure 23(b)(2)  and Rule 23(b)(3) on behalf of himself and all others similarly situated and seeks certification of  the following Class:  Autodialed No Consent Class: All persons in the United States who from four  years prior to the filing of this action (1) Defendant (or an agent acting on behalf of  Defendant) called/texted, (2) on the person’s cellular telephone, (3) using  substantially the same equipment used to call/text Plaintiff, (4) for substantially the  same reason Defendant called/texted Plaintiff, and (5) for whom Defendant claims  (a) it obtained consent in the same manner as Defendant claims it obtained consent  to call/text Plaintiff, or (b) Defendant did not obtain consent.   23.  The following individuals are excluded from the Class: (1) any Judge or  Magistrate presiding over this action and members of their families; (2) Defendant, its  subsidiaries, parents, successors, predecessors, and any entity in which Defendant or its parents  have a controlling interest and their current or former employees, officers and directors; (3)  Plaintiff’s attorneys; (4) persons who properly execute and file a timely request for exclusion  from the Class; (5) the legal representatives, successors or assigns of any such excluded persons;  and (6) persons whose claims against Defendant have been fully and finally adjudicated and/or  released. Plaintiff anticipates the need to amend the Class definitions following appropriate  discovery.   24.  Numerosity: On information and belief, there are hundreds, if not thousands of  members of the Class such that joinder of all members is impracticable.   28.  Plaintiff repeats and realleges paragraphs 1-27 of this Complaint and incorporates  them by reference.   29.  Defendant and/or its agents sent unsolicited text messages to cellular telephone  numbers belonging to Plaintiff and the other members of the Autodialed No Consent Class using  an autodialer.   30.  These text messages were sent en masse without consent.   31.  Defendant sent these text messages negligently or willfully and knowingly.   9.  In violation of the TCPA, Defendant sends autodialed text messages to consumers  without consent.   Class Treatment Is Appropriate for Plaintiff’s TCPA Claim   Life for Relief Sends Autodialed Text Messages   to Consumers’ Cellular Phone Numbers Without Consent    Life for Relief Repeatedly Texted Plaintiff’s   Cell Phone Number Without Plaintiff’s Consent   Telephone Consumer Protection Act   (Violation of 47 U.S.C. § 227)  (On Behalf of Plaintiff and the Autodialed No Consent Class)  