14.  Plaintiff brings this action on behalf of herself and on behalf of and all  others similarly situated (“the Class”).   15.  Plaintiff represents, and is a member of the Class, consisting of all  persons within the United States who receive any unsolicited telephone calls from  Defendant or its agents on their paging service, cellular phone service, mobile  radio service, radio common carrier service, or other service for which they were  charged for the call, through the use of any automatic telephone dialing system or  artificial or pre-recorded voice system as set forth in 47 U.S.C. Section  227(B)(1)(A)(3) or artificial or prerecorded voice, which telephone call by  Defendant or its agents was not made for emergency purposes or with the  recipients’ prior express consent, within the four years prior to the filing of this  Complaint.   16.  Defendant and its employees or agents are excluded from the Class.   Plaintiff does not know the number of members in the Class, but believes the Class  members number in the hundreds of thousands, if not more.  Thus, this matter  should be certified as a Class action to assist in the expeditious litigation of this  matter.   26.  Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   27.  The foregoing acts and omissions of Defendant and its agents  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.   28.  As a result of Defendant’s, and Defendant’s agents’, negligent  violations of 47 U.S.C. § 227 et seq, Plaintiff 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).   29.  Plaintiff and the Class are also entitled to and seek injunctive relief  prohibiting such conduct in the future.  30.  Plaintiff incorporates by reference the above paragraphs 1 through 25  inclusive, of this Complaint as though fully stated herein.   34.  As a result of Defendant’s, and Defendant’s agents’, negligent  violations of 47 U.S.C. § 227(b)(1), Plaintiff seeks for herself and each Class  member $500.00 in statutory damages, for each and every violation, pursuant to 47  U.S.C. § 227(b)(3)(B).   35.  Pursuant to 47 U.S.C. § 227(b)(3)(A), Plaintiff seeks injunctive relief  prohibiting such conduct in the future.   36.  Any other relief the Court may deem just and proper.  8.   Commencing approximately January of 2012, through the present,  Plaintiff Lidia Riott received a number of unsolicited phone calls to her wireless  phone, for which Plaintiff provided no consent to call, requesting Plaintiff Lidia  Riott to purchase various vacation packages.     9.  Plaintiff Lidia Riott has attempted to unsubscribe to Defendant’s  network, however continues to receive a number of unsolicited phone calls.      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.   THE TCPA, 47 U.S.C. § 227 ET SEQ.   VIOLATION OF THE TCPA, 47 U.S.C. § 227 ET SEQ.  