25.  Defendant FortuneBuilders, Inc. is a real estate investing education company.  During or before May 2015, in an effort to solicit potential and former customers, FortuneBuilders,  Inc. recruited, or employed call centers, to place telephone calls, en masse, to consumers across  the country. On information and belief, Defendant and or their agents purchase “leads” containing  consumers’ contact information and create electronic databases from which Defendant makes  automated calls.    26.  In Defendant’s overzealous attempt to market its services, they placed phone calls  to consumers who never provided consent to call, and to consumers having no relationship with  Defendant. Worse yet, Defendant placed repeated and unwanted calls to consumers whose phone  numbers are listed on the National Do Not Call Registry. Consumers place their phone numbers  on the Do Not Call Registry for the express purpose of avoiding unwanted telemarketing calls like  those alleged here.   27.  Defendant knowingly made these telemarketing calls without the prior express  written consent of the call recipients, and knowingly continue to call them after requests to stop.  As such, Defendant not only invaded the personal privacy of Plaintiff and members of the putative  Class, but also intentionally and repeatedly violated the TCPA.  42.  Plaintiff has standing to bring this suit on behalf of herself and the members of the  class under Article III of the United States Constitution because Plaintiff’s claims state: (a) a valid  injury in fact; (b) an injury which is traceable to the conduct of Defendant; and (c) is likely to be  redressed by a favorable judicial decision.  See Spokeo v. Robins, 578 U.S. __ (2016) at 6; Robins  v. Spokeo, 867 F.3d 1108 (9th Cir. 2017) (cert denied. 2018 WL 491554, U.S., Jan. 22 2018);  Lujan v. Defenders of Wildlife, 504 U.S. 555, 560 (1992); and Chen v. Allstate Inc. Co., 819 F.3d  1136 (9th Cir. 2016).    43.  Plaintiff’s injuries must be both “concrete” and “particularized” in order to satisfy  the requirements of Article III of the Constitution.  (Id.)    71.  Plaintiff re-alleges and incorporates by reference each preceding paragraph as  though set forth at length herein.   72.  47 U.S.C. § 227(c) provides that any “person who has received more than one  telephone call within any 12-month period by or on behalf of the same entity in violation of the  regulations prescribed under this subsection may” bring a private action based on a violation of  said regulations, which were promulgated to protect telephone subscribers’ privacy rights to avoid  receiving telephone solicitations to which they object.    73.  The TCPA’s implementing regulation—47 C.F.R. § 64.1200(c)—provides that  “[n]o person or entity shall initiate any telephone solicitation” to “[a] residential telephone  subscriber who has registered his or her telephone number on the national do-not-call registry of  persons who do not wish to receive telephone solicitations that is maintained by the federal  government.” See 47 C.F.R. § 64.1200(c).   A.  CLASS ALLEGATIONS   VIOLATION OF TCPA, 47 U.S.C. § 227  (“DNC Claim” On behalf of Plaintiff and the DNC Class)  