24.  Plaintiffs bring this action on behalf of themselves and on behalf of all  others similarly situated (“the Class”).   35.  Plaintiffs incorporate by reference all of the above paragraphs of this  Complaint as though fully stated herein.   40.  Plaintiffs incorporate by reference the above paragraphs 1 through 34  inclusive, of this Complaint as though fully stated herein.   41.  Each such text message call 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. By using such  equipment, Defendant was able to effectively send thousands of text messages  simultaneously to lists of thousands of wireless phone numbers of consumers  without human intervention.  These text messages were made en masse through the  use of a short code and without the prior express consent of the Plaintiffs and the  other members of the Class to receive such text messages.   45.  As a result of Defendant’s, and Defendant’s agents’, negligent  violations of 47 U.S.C. § 227(b)(1), Plaintiffs seek for themselves and each Class  member $500.00 in statutory damages, for each and every violation, pursuant to 47  U.S.C. § 227(b)(3)(B).   46.  Pursuant to 47 U.S.C. § 227(b)(3)(A), Plaintiffs seek injunctive relief  prohibiting such conduct in the future.   47.  Any other relief the Court may deem just and proper.  9.    One of the newest types of bulk marketing is to advertise through  Short Message Services. The term “Short Message Service” or “SMS” is a  messaging system that allows cellular telephone subscribers to use their cellular  telephones to send and receive short text messages, usually limited to 160  characters.   Cite the U.S. Civil Statute under which you are filing  (Do not cite jurisdictional statutes unless diversity): Brief description of cause: VII.  REQUESTED IN 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.   VIOLATION OF THE TCPA, 47 U.S.C. § 227 ET SEQ.  