24.  On or about March 13, 2020, Defendant caused the following automated text  message to be transmitted to Plaintiff’s cellular telephone number ending in 3993 (“3993  Number”):   25.  Plaintiff is the sole user of the 3993 number.    26.  Defendant’s text message constitutes telemarketing/advertising because it  promotes Defendants business, goods and services.   27.  Specifically, the text messages promote Defendant’s golfing membership  services.   47.  Plaintiff brings this case as a class action pursuant to Fed. R. Civ. P. 23, on  behalf of himself and all others similarly situated.   48.  Plaintiff brings this case on behalf of the below defined Class:  All persons within the United States who, within  the four years prior to the filing of this Complaint,  were sent a text message using the same type of  equipment used to text message Plaintiff, from  Defendant or anyone on Defendant’s behalf, to  said person’s cellular telephone number, for the  purpose  of  advertising  and/or  promoting  Defendant’s goods and/or services.    49.  Plaintiff reserves the right to modify the Class definitions as warranted as facts  are learned in further investigation and discovery.    50.  Defendant and its employees or agents are excluded from the Class. Plaintiff  does not know the number of members in the Class but believes the members of the Class  number in the several thousands, if not more.  53.  There are numerous questions of law and fact common to the Class which  predominate over any questions affecting only individual members of the Class.  Among  the questions of law and fact common to the Class are:  (1) Whether Defendant made non-emergency calls to Plaintiff and the  Class Members’ cellular or residential telephones using an ATDS;  (2) Whether Defendant can meet its burden of showing that they obtained  prior express written consent to make such calls;  (3) Whether Defendant’s conduct was knowing and willful;  (4) Whether Defendant is liable for damages, and the amount of such  damages; and  (5) Whether Defendant should be enjoined from such conduct in the  future.   54.  The common questions in this case are capable of having common answers.  If Plaintiff’s claims that Defendant routinely transmits text messages to cellular telephone  numbers is accurate, Plaintiff and the Class members will have identical claims capable of  being efficiently adjudicated and administered in this case.  59.  Plaintiff re-alleges and incorporates the foregoing allegations as if fully set  forth herein.    PROPOSED CLASS   Violation of the TCPA, 47 U.S.C. § 227  (On Behalf of Plaintiff and the Class)  