10.  FHL is wholly owned by Defendant.   11.  Furthermore, Defendant does business as FHL in states where it is  allowed to do so and does business as “InterContinental Capital Group, Inc.” in  states where it is not, e.g., the State of New York.   23.  Plaintiff brings this action individually and on behalf of all others  similarly situated, as a member the two proposed classes (hereafter, jointly, “The  Classes”).    24.  The class concerning the ATDS claim for no prior express consent  (hereafter “The ATDS Class”) is defined as follows:  All persons within the United States who received any  solicitation/telemarketing  telephone  calls  from  Defendant to said person’s cellular telephone made  through the use of any automatic telephone dialing  system or an artificial or prerecorded voice and such  person had not previously consented to receiving such  calls within the four years prior to the filing of this  Complaint   25.  The class concerning the National Do-Not-Call violation (hereafter  “The DNC Class”) is defined as follows:  All persons within the United States registered on the  National Do-Not-Call Registry for at least 30 days, who  had not granted Defendant prior express consent nor had  a prior established business relationship, who received  more than one call made by or on behalf of Defendant  that promoted Defendant’s products or services, within  any twelve-month period, within four years prior to the  filing of the complaint.   8.  Beginning in or around May of 2016, Defendant contacted Plaintiff  on Plaintiff’s cellular telephone number ending in -9695, in an attempt to solicit  Plaintiff to purchase Defendant’s services.     9.  Defendant identified itself as “Fellowship Home Loans” (“FHL”).   Knowing and/or Willful Violations of the Telephone Consumer Protection  Act   47 U.S.C. §227(b)   As a result of Defendant’s willful and/or knowing violations of 47  U.S.C. §227(b)(1), Plaintiff and the ATDS Class members are  entitled to and request treble damages, as provided by statute, up to  $1,500, for each and every violation, pursuant to 47 U.S.C.  §227(b)(3)(B) and 47 U.S.C. §227(b)(3)(C).    Any and all other relief that the Court deems just and proper.   Negligent Violations of the Telephone Consumer Protection Act  47 U.S.C. §227(c)   As a result of Defendant’s negligent violations of 47 U.S.C.  §227(c)(5), Plaintiff and the DNC Class members are entitled to and  request $500 in statutory damages, for each and every violation,  pursuant to 47 U.S.C.  227(c)(5).    Any and all other relief that the Court deems just and proper. 