10.  Defendant’s calls constituted calls that were not for emergency  purposes as defined by 47 U.S.C. § 227(b)(1)(A).   11.  Defendant’s calls were placed to telephone number assigned to a  cellular telephone service for which Plaintiff incur a charge for incoming calls  pursuant to 47 U.S.C. § 227(b)(1).    13.  Plaintiff bring this action on behalf of themselves and all others  similarly situated, as a member of the proposed class (hereafter “The Class”)  defined as follows:  All persons within the United States who received any  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   14.  Plaintiff represent, and are members of, The Class, consisting of All  persons within the United States who received any 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 not provided their cellular telephone number to Defendant within the  four years prior to the filing of this Complaint.   15.  Defendant, its employees and agents are excluded from The Class.   Plaintiff do not know the number of members in The Class, but believes the Class  members number in the thousands, if not more.  Thus, this matter should be  certified as a Class Action to assist in the expeditious litigation of the matter.   8.    Beginning in or around August of 2018, Defendant contacted Plaintiff  on his cellular telephone, number ending in -3074, in an effort to sell or solicit its  services.   9.   Defendant used an “automatic telephone dialing system”, as defined  by 47 U.S.C. § 227(a)(1) to place its daily calls to Plaintiff seeking to sell or solicit  its business services.   Knowing and/or Willful Violations of the Telephone Consumer Protection Act   47 U.S.C. §227 et seq.   As a result of Defendant’s willful and/or knowing violations of 47 U.S.C. §227(b)(1), Plaintiff and the 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); and  Any and all other relief that the Court deems just and proper. Respectfully Submitted this 7th Day of May, 2019. 