19.  Beginning in or about the second half of 2013, Defendants called  Plaintiff’s cellular telephone number.     20.  Plaintiff’s telephone number is, and was at all relevant times, assigned  to a cellular telephone service, as set forth in 47 U.S.C. 227(b)(1).   21.  Plaintiff is the authorized and sole user of the cellular telephone  number that Defendants called.   39.  Plaintiff brings this action on behalf of herself and on behalf of all  others similarly situated (“the Class”).   53.  Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   54.  Plaintiff brings this cause of action against Defendants on behalf of  herself and on behalf of the Class.   55.  Defendants, either directly or through their agents, using an ADTS or  an artificial or prerecorded voice, made calls to Plaintiff and the other Class  Members at telephone numbers assigned to a paging service, cellular telephone  service, specialized mobile radio service, or other radio common carrier service, or  any service for which the called party is charged or pays a monthly payment for the  call.  Defendants did not make the calls for emergency purposes and did not make  the calls with the prior express consent of the called party.   56.  The foregoing acts and omissions of Defendants and their 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.   58.  Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   59.  Plaintiff brings this cause of action against Defendants on behalf of  herself and on behalf of the Class.   60.  Defendants, either directly or through their agents, using an ADTS or  an artificial or prerecorded voice, made calls to Plaintiff and the other Class  Members at telephone numbers assigned to a paging service, cellular telephone  service, specialized mobile radio service, or other radio common carrier service, or  any service for which the called party is charged for the call.  Defendants did not  make the calls for emergency purposes and did not make the calls with the prior  express consent of the called party.   61.  The foregoing acts and omissions of Defendants constitute 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.   62.  As a result of Defendants’ 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).   64.  Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated therein.   65.  Plaintiff brings this cause of action against Defendants on behalf of  herself and on behalf of the Class or, in the alternative, the California Sub-Class.   66.  Defendants are “persons” as defined by California Civil Code section  1761(c).   67.  Plaintiff and the other Class Members are “consumers” within the  meaning of California Civil Code § 1761(d).   68.  The CLRA makes unlawful certain enumerated “unfair methods of  competition and unfair or deceptive acts or practices undertaken by any person in a  transaction intended to result or which results in the lease of goods or services to  any consumer[.]”  Cal. Civ. Code § 1770(a).   69.  Among those practices the CLRA expressly proscribes is  “[d]isseminating an unsolicited prerecorded message by telephone without an  unrecorded, natural voice first informing the person answering the telephone of the  name of the caller or the organization being represented, and either the address or  the telephone number of the caller, and without obtaining the consent of that person  to listen to the prerecorded message.”  Cal. Civ. Code § 1770(a)(22)(A).   70.  Exempted from that proscription is “a message disseminated to a  business associate, customer, or other person having an established relationship  with the person or organization making the call, to a call for the purpose of  collecting an existing obligation, or to any call generated at the request of the  recipient.”  Cal. Civ. Code § 1170(a)(22)(B).   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.   VIOLATIONS OF CALIFORNIA’S CONSUMERS   LEGAL REMEDIES ACT  CAL. CIV. CODE § 1770(a)(22).   VIOLATIONS OF CALIFORNIA’S UNFAIR COMPETITION LAW  CAL. BUS. & PROF. CODE §§ 17200, ET SEQ.  