21.  Plaintiff Jennifer Stephens does not have any credit cards associated  with Defendant and has never provided Defendant with her cellular phone number.   22.  However, despite having no account with Defendant, beginning in or  around January 2017, Plaintiff Jennifer Stephens began receiving unsolicited phone  calls from Defendant to her wireless phone, for which Plaintiff Jennifer Stephens  provide no consent to call, attempting to collect on an alleged Victoria Secret debt  owed by her adult daughter.   23.  Among other unsolicited calls from Defendant, Plaintiff Jennifer  Stephens has received calls on January 20, 2017 from the number 303-255-5000,  January 26, 2017 from the number 208-635-7403, February 7, 2017 from an  unknown number, February 10, 2017 from the number 855-334-4197 and on  February 16, 2017 from the number 855-334-4197.  These numbers are owned by  Defendant.    24.  When answered, during each of these calls there was prolonged silence  and delays prior to being connected to a live representative.    25.  Plaintiff requested that Defendant stop calling her on her cellular phone  and that Defendant had the wrong number, however the calls continued.     26.  Like Plaintiff Jennifer Stephens, Plaintiff Christopher Gulley does not  have any credit cards associated with Defendant and has never provided Defendant  with his cellular phone number.   37.  Plaintiffs bring this action on behalf of themselves and on behalf of all  others similarly situated (“the Class”).   38.  Plaintiffs represent, and are members of the Class, consisting of all  persons within the United States who: (1) received a telephone call from Defendant  or its agents; (2) on his or her cellular telephone number; (3) through the use of any  automatic telephone dialing systems or artificial or prerecorded voice 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, within four years prior to the  filing of the Complaint through the date of final approval.     39.  Defendant and its employees or agents are excluded from the Class.     40.  Plaintiffs do not know the exact number of members in the Class, but  believe 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.   41.  Plaintiffs and members of the Class were harmed by the acts of  Defendant in at least the following ways: Defendant, either directly or through its  agents, illegally contacted Plaintiffs and the Class members via their cellular  telephones by using unsolicited telephone calls, thereby causing Plaintiffs and the  Class members to incur certain cellular telephone charges or reduce cellular  telephone time for which Plaintiffs and the Class members previously paid, and  invading the privacy of said Plaintiffs and the Class members.  Plaintiffs and the  Class members were damaged thereby.   47 U.S.C. §§ 227 ET SEQ.   50.  Plaintiffs incorporate by reference all of the above paragraphs of this  Complaint as though fully stated herein.   51.  Each such telephone call 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 simultaneously to lists of thousands of  consumers’ wireless phone numbers without human intervention.     52.  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.   53.  As a result of Defendant’s, and Defendant’s agents’, negligent  violations of 47 U.S.C. § 227 et seq., Plaintiffs 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).   54.  Plaintiffs and the Class are also entitled to and seek injunctive relief  prohibiting such conduct in the future.  60.  As a result of Defendant’s, and Defendant’s agents’, negligent  violations of 47 U.S.C. § 227(b)(1), Plaintiffs seek 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).   61.  Pursuant to 47 U.S.C. § 227(b)(3)(A), Plaintiffs seek injunctive relief  prohibiting such conduct in the future.   63.  As a result of Defendant’s, and Defendant’s agents’, willful and/or  knowing violations of 47 U.S.C. § 227(b)(1), Plaintiffs seek for themselves 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).   64.  Pursuant to 47 U.S.C. § 227(b)(3)(A), injunctive relief prohibiting such  conduct in the future.   65.   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.  