(Knowing and/or Willful Violations of the Telephone Consumer Protection Act, 47 U.S.C.  § 227(b)(1)(A))   (Violations of the Telephone Consumer Protection Act, 47 U.S.C. § 227(b)(1)(A))   14.  Pivotal Payments is a “leading provider of technology-driven global payment  processing solutions for small to large enterprises.”  See http://www.pivotalpayments.com/about- us/pivotal-payments (last visited September 14, 2016).   15.  Pivotal Payments “deliver[s] the best payment acceptance strategies” to its clients  by operating “multiple divisions dedicated to specific industry segments.”  Id.   16.  One such division is Capital Processing Network or CPN (“CPN”), which Pivotal  Payments acquired in 2014.  See http://www.pivotalpayments.com/press-release/pivotal- payments-acquires-key-assets-capital-processing-network-llc (last visited September 14, 2016).   91.  Plaintiff realleges and incorporates by reference each and every allegation set  forth in the preceding paragraphs.   92.  The foregoing acts and omissions of Pivotal Payments and/or its affiliates, agents,  and/or other persons or entities acting on Pivotal Payments’ behalf constitute numerous and  multiple violations of the TCPA, 47 U.S.C. § 227(b)(1)(A), by making calls, except for  emergency purposes, to the cellular telephone numbers of Plaintiff and members of the Class  using an ATDS and/or artificial or prerecorded voice.   93.  As a result of Pivotal Payments’ and/or its affiliates, agents, and/or other persons  or entities acting on Pivotal Payments’ behalf’s violations of the TCPA, 47 U.S.C.  § 227(b)(1)(A), Plaintiff and members of the Class presumptively are entitled to an award of  $500 in damages for each and every call made to their cellular telephone numbers using an  ATDS and/or artificial or prerecorded voice in violation of the statute, pursuant to 47 U.S.C.  § 227(b)(3)(B).   94.  Plaintiff and members of the Class are also entitled to and do seek injunctive  relief prohibiting Pivotal Payments and/or its affiliates, agents, and/or other persons or entities  acting on Pivotal Payments’ behalf from violating the TCPA, 47 U.S.C. § 227(b)(1)(A), by  making calls, except for emergency purposes, to any cellular telephone numbers using an ATDS  and/or artificial or prerecorded voice in the future.  95.  Plaintiff realleges and incorporates by reference each and every allegation set  forth in the preceding paragraphs.   A.  Factual Allegations Regarding Pivotal Payments  