20.  SquareTwo and CACH purchase charged-off debts and then attempt to  collect on alleged debts owed.  Once an alleged debt is purchased, SquareTwo and  CACH place the accounts for collection within their network of branch offices.     21.  Mandarich Law is a member of SquareTwo’s and CACH’s network of  branch offices.     22.  As a part of that network, Mandarich Law exclusively performs debt  collection services at the direction of and for the benefit of SquareTwo and CACH.   See http://www.mandarichlaw.com/faqs (last visited on September 20, 2016).  As a  part of that network, SquareTwo and CACH actively monitor Mancarich Law’s debt  collection efforts.   23.  In an effort to collect on alleged debts owed, SquareTwo and CACH  engaged and directed Mandarich Law to place thousands of unsolicited phone calls  to consumers nationwide. At all times relevant Mandarich Law worked exclusively  on behalf of SquareTwo and CACH and “utilized [their] account management  system” in their debt collection efforts.  http://d1lge852tjjqow.cloudfront.net/CIK- 0001505966/3aed6172-0c9d-456e-a695-ce0f51dfcfab.pdf?noexit=true   24.  Beginning around at least November 2013, although Plaintiff never  provided Defendants with his cellular number or consent to contact him on his  cellular number, Plaintiff began receiving unsolicited phone calls from Mandarich  Law, attempting to collect on an alleged debt owed on behalf of SquareTwo and  36.  Plaintiff brings this action pursuant to Federal Rule of Civil Procedure  23(b)(2) and 23(b)(3) on behalf of himself and on behalf of and all others similarly  situated (“the Class”).   47 U.S.C. §§ 227 ET SEQ.   48.  Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   49.  Each such telephone 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, and to dial such numbers.   By using such equipment, Defendants were able to effectively make thousands of  phone calls simultaneously to lists of thousands of wireless phone numbers of  consumers without human intervention.      50.  The foregoing acts and omissions of Defendants and their agents  constitute numerous and multiple negligent violations of the TCPA, including but  not limited to each and every one of the above-cited provisions of 47 U.S.C. § 227  et seq.   51.  As a result of Defendants’ and Defendants’ agents’ negligent violations  of 47 U.S.C. § 227 et seq., Plaintiff 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).   52.  Plaintiff and the Class are also entitled to and seek injunctive relief  prohibiting such conduct in the future.  53.  Plaintiff incorporates by reference paragraphs 1-47 of this Complaint  as though fully stated herein.     58.  As a result of Defendants’ and Defendants’ agents’ negligent violations  of 47 U.S.C. § 227(b)(1), Plaintiff seeks for himself and each Class member $500.00  in statutory damages, for each and every violation, pursuant to 47 U.S.C. §  227(b)(3)(B).   59.  Pursuant to 47 U.S.C. § 227(b)(3)(A), Plaintiff seeks injunctive relief  prohibiting such conduct in the future.  KNOWING AND/OR WILLFUL VIOLATIONS OF THE TCPA  47 U.S.C. §§ 227 ET SEQ.   NEGLIGENT VIOLATIONS OF THE TCPA  47 U.S.C. §§ 227 ET SEQ.  