20.  Commencing no later than September 18, 2016, Plaintiff began  receiving unsolicited phone calls to his wireless phone ending in the number -0806,  for which Plaintiff provided no consent to call.      38.  Plaintiff brings this action on behalf of himself and on behalf of all  others similarly situated (“the Class”).   39.  Plaintiff represents, and is a member of the following Classes:  Auto-Dialer Class:  Any person in the United States who (1) Defendant or its  agents placed a call; (2) to that person’s cellular telephone number; (3)  through the use of any automatic telephone dialing system as set forth in 47  U.S.C. § 227(b)(1)(A)(3); and (4) where Defendant has no record of prior  express consent for such individual to make such call or where the individual  revoked consent, within four years prior to the filing of the Complaint through  the date of final approval.   Text Message Class:  Any person in the United States who (1) Defendant or  its agents placed a text message call; (2) to that person’s cellular telephone  number; (3) through the use of any automatic telephone dialing system as set  forth in 47 U.S.C. § 227(b)(1)(A)(3); and (4) where Defendant has no record  of prior express consent for such individual to make such text message call or  where the individual revoked consent, within four years prior to the filing of  the Complaint through the date of final approval.    40.  Defendant and its employees or agents are excluded from the Class.     41.  Plaintiff does not know the exact 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.   47 U.S.C. §§ 227 ET SEQ.   51.  Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   52.  Each such telephone call and text message described herein was made  using equipment that, upon information and belief, had the capacity to store or  produce telephone numbers to be called, using a random or sequential number  generator, and to dial such numbers.  By using such equipment, Defendant was able  to in effect make hundreds or thousands of phone calls and/or text messages  simultaneously to lists of thousands of consumers’ wireless phone numbers without  human intervention.     53.  The foregoing acts and omissions by Defendant and its agents  constitute numerous and multiple negligent violations of the TCPA, including but  not limited to each of the above-cited provisions of 47 U.S.C. § 227 et seq.   56.  Plaintiff incorporates by reference the above paragraphs 1 through 43  inclusive, of this Complaint as though fully stated herein.   57.  Each such telephone call and text message was made using equipment  that, upon information and belief, had the capacity to store or produce telephone  numbers to be called, using a random or sequential number generator, and to dial  such numbers.  By using such equipment, Defendant was able to in effect make  hundreds or thousands of phone calls simultaneously to lists of thousands of  consumers’ wireless phone numbers without human intervention.      58.  The foregoing acts and omissions by Defendant and its agents  constitute numerous and multiple knowing and/or willful violations of the TCPA,  including but not limited to each of the above-cited provisions of 47 U.S.C. §§ 227  et seq.   59.  As a result of Defendant’s knowing and/or willful violations of 47  U.S.C. § 227 et seq., Plaintiff and the Class are entitled to treble damages, as  provided by statute, up to $1,500.00, for each and every violation, pursuant to 47  U.S.C. § 227(b)(3)(B) and 47 U.S.C. § 227(b)(3)(C).    60.  Plaintiff and the Class are also entitled to and seek injunctive relief  prohibiting such conduct in the future.  61.  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).   62.  Pursuant to 47 U.S.C. § 227(b)(3)(A), Plaintiff seeks injunctive relief  prohibiting such conduct in the future.   63.  Any other relief the Court may deem just and proper.  64.  As a result of Defendant’s, and Defendant’s agents’, willful and/or  knowing violations of 47 U.S.C. § 227(b)(1), Plaintiff seeks for herself and each  Class member treble damages, as provided by statute, up to $1,500.00 for each and  every violation, pursuant to 47 U.S.C. § 227(b)(3)(B) and 47 U.S.C. § 227(b)(3)(C).   65.  Pursuant to 47 U.S.C. § 227(b)(3)(A), injunctive relief prohibiting such  conduct in the future.   66.   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.   VIOLATION OF THE TCPA, 47 U.S.C. §§ 227 ET SEQ.  