10.  Plaintiff alleges that at all times relevant herein Defendant conducted  business within this judicial district.   11.  At no time did Plaintiff ever enter into a business relationship with  Defendant.   12.  Beginning in 2017, Plaintiff began receiving telephonic communications  from Defendant in order to solicit Plaintiff’s business.   13.  As part of these solicitation efforts, Defendant’s automated voice asked  Plaintiff three questions.   14.  Only after answering these questions was Plaintiff transferred to a live agent.   15.  Thereafter, Defendant’s agent inquired as to whether Plaintiff was interested  in taking a cruise.    16.  Plaintiff answered in the negative which prompted Defendant’s agent to end  the call.   17.  On information and belief, Plaintiff has not utilized Defendant’s services nor  requested said services at any time.   18.  Defendant used an “automatic telephone dialing system”, as defined by 47  U.S.C. § 227(a)(1) to send the artificial or prerecorded message to Plaintiff  as prohibited by 47 U.S.C. § 227(b)(1)(A).   27.  Plaintiff brings this action on behalf of himself and on behalf of all others  similarly situated (“the Class”).   39.  Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   40.  The foregoing acts and omissions of Defendant constitutes 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.   41.  As a result of Defendant’s 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).   43.  Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   44.  The foregoing acts and omissions of Defendant constitutes numerous and  multiple knowing and/or willful 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.   45.  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 an award of $1,500.00 in  statutory damages, for each and every violation, pursuant to 47 U.S.C. §  227(b)(3)(B) and 47 U.S.C. § 227(b)(3)(C).   46.  Plaintiff and the Class are also entitled to and seek injunctive relief  prohibiting such conduct in the future.  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.  •   As a result of Defendant’s knowing and/or willful violations of 47 U.S.C.  § 227(b)(1), Plaintiff seeks for himself and each Class member $1,500.00  in statutory damages, for each and every violation, pursuant to 47 U.S.C.  § 227(b)(3)(B).  •   Pursuant to 47 U.S.C. § 227(b)(3)(A), injunctive relief prohibiting such  conduct in the future.  •   Any other relief the Court may deem just and proper. 