(On behalf of Plaintiff and the Class)   78.  Plaintiff incorporates by reference the foregoing allegations as if fully set forth  herein.   79.  Defendants and their agents made unsolicited text message calls to cellular  telephone numbers belonging to Plaintiff and the other members of the Class  en masse without their prior express consent.   80.  Defendants made the text message calls, or had them made on their behalf,  using equipment that had the capacity to store or produce telephone numbers  to be called using a random or sequential number generator, and to dial such  numbers.   81.  Defendants and their agents utilized equipment that made, or had made on  their behalf, the text message calls to Plaintiff and other members of the Class  simultaneously and without human intervention.   83.  Should the Court determine that Defendants’ conduct was willful and  knowing, the Court may, pursuant to section 227(b)(3)(C), treble the amount  of statutory damages recoverable by Plaintiff and the other members of the  Class. 