1.  (773) 717-5652;  j.  (361) 271-4092; and  k.  (310) 773-5113.   14.  In March of 2015, Plaintiff began receiving phone calls on his cellular phone from  a phone number that was unknown to him - (469) 619-6420 - that appeared to have been  initiated by an automatic telephone dialing system.   15.  Plaintiff believes that an automatic telephone dialing system was used, because of  the customary delay at the beginning of each call before Plaintiff was able to speak with a live  operator or before a live operator was able to leave a message in Plaintiffs voice mail.   16.  Each of the phone calls solicited Plaintiff for a "business funding" or a loan.   18.  After Plaintiff began receiving these calls, he immediately advised the callers that  he was not interested in any funding.   19.  Plaintiff also advised the callers that they were calling his cell phone line and that  they should immediately cease all such solicitation calls.   20.  Nonetheless, the calls continued.  r-  21.  After receiving additional calls, on June 19, 2015, Plaintiff registered his cell  phone number with the national "Do Not Call" list.   22.  However, the calls still continued and were now generated from different phone  numbers, including:  a.  ( 646) 873-6264  b.  (404) 537-1730;  c.  (512) 640-6225;  d.  (513) 898-3804;  e.  (239) 307-6112;  f.  (239) 307-6113;  g.  (404) 382-5273;  h.  (305) 424-8441;   24.  However, the calls persisted.   25.  Although the phone numbers used to call Plaintiff varied, they were all a part of a  single, coordinated solicitation effort, because they were referenced and used by the callers  interchangeably.   26.  Indeed, when Plaintiff began receiving phone calls from phone numbers other  than (469) 619-6420, the subsequent voice mails asked Plaintiff to nonetheless call back that  number.   27.  For instance on August 21, 2015, and, again, on August 28, 2015, Plaintiff  received a call and a subsequent voice mail from "Michael Ward," who appeared to have been  calling from (646) 873-6264.   28.  The voice mails left by "Michael Ward" were identical in content (i.e., Plaintiff  was asked about "eligibility for additional funding") and, on each occasion, Plaintiff was asked  to call back (469) 619-6420 -the original number that was used to call Plaintiff in the Spring of  2015.   29.  In similpr fashion, a voice mail left by "Lou," following a call of December 29,  2015, that appeared to have originated from (646) 873-6264 - a phone number used to call  Plaintiff in August of 2015, now asked Plaintiff to call back (404) 537-1730-'- a different phone  number that was used to call Plaintiff and leave a similar voice mail on December 22, 2015.   31.  Although the callers provided different names - "Michael Ward," "Jason,"  "Justin," "Jimmy," "Portia," "Philip," "Stella," "Larry," "Kyle," "Lou;" "Miles," "Theo," "Carl,"  "Bruce Parker," "Jim Carson," "Jenny," "Tom," "Jonathan," "Samantha," "Jeremy," "Chad,"  "Lucas," "Jane," "Janie," "Jake," "Ethan," "Elliot," "Tom Walters," "Josh Greenberg," "Frank  Staley," "Patrick," "Carl," "Mark," "Tyler," "Roy," and "Shane" - the substance of the calls  and/or voice messages was always the same; namely, Plaintiff was being solicited for a loan.   32.  During some of these calls, the callers disclosed that they were calling on behalf  of "Fast Capital."   33.  For instance, on January 12, 2017, Plaintiff received the following messagej from  (51~) 898-3804, in his voice mail box:  Hello this is Patrick calling from Fast Capital. My company helps  businesses grow by providing flexible funding when you need it.  Please give me a call when you have a moment to discuss some  options that you might have.  Once again Pat here from Fast  Capital. Thank you and have a great day.   34.  In sum, since March of 2015, Plaintiff received a total of - at least - 115 such  phone calls from Defendants to his cellular phone, including:  a.  More than 100 calls after Plaintiff repeatedly asked not to be called;  b.  No less tha,n 112 calls after Plaintiff registered his cell phone with the  national "Do Not Call" list; and  c.  No less than 105 calls after Plaintiff re-registered his cell phone with the  national "Do Not Call" list.   36.  On February 1, 2017, after receiving yet another phone call and a voice message,  Plaintiff decided to call back the phone number (646) 873-6264 to determine where the phone  calls were coming from.   37.  During a brief conversation, Plaintiff was explicitly told that he was being called  by "Fast Capital 360" to solicit him for a loan.   38.  Plaintiff was then invited to review Defendants' profile and rating on  www.trustpilot.com. See https://www.trustpilot.com/review/fastcapital360.com, last visited on  March 1, 2017.   39.  Before he began receiving calls from Defendants in the Spring of 2015, Plaintiff  has never had any interactions or dealings with them.   40.  Defendants knew or should have known that their actions violated the TCP A.   41.  Defendants could have taken the steps necessary to bring their actions into  compliance with the TCP A, but Defendants neglected to do so and failed to adequately review  those actions to insure compliance with the law.   42.  Defendants' conduct, as alleged herein, is (and was) deliberate, intentional,  reckless, willful, and wanton.   43.  Defendants' conduct, as alleged herein, violated the TCPA in that they initiated  numerous telemarketing telephone calls to Plaintiffs cellular telephone, using an automatic  telephone dialing system, for non-emergency purposes, without Plaintiffs consent (and, in fact,  after Plaintiff requested that these calls cease).   45.  Plaintiff and the members of the Class have been (and will continue to be)  damaged due to Defendants' violations of the TCP A, as set forth herein .  . 46.  Plaintiff and the members of the Class have suffered and will continue to suffer  actual damages due to Defendants' conduct, as set forth herein.  4 7.  Left unabated, Defendants will continue to disregard the protections afforded by  the TCPA.  48.  Plaintiff brings this action on behalf of himself and similarly-situated individuals  pursuant to F ed.R. Civ .P. 23.   49.  Plaintiff brings this action as a nationwide class action for Defendants' violations  .,  of the TCP A on behalf of the following class of individuals:  All persons and entities throughout the United States, to whpm  Defenf}ants placed, or caused to be placed, a telephone call,  directed to a number assigned to a cellular telephone service, by  using an automatic telephone dialing system, within four years  preceding the date of this complaint (hereinafter "Class").   51.  Plaintiff will fairly and adequately protect the interests of the Class, and has  retained counsel that is experienced and competent in class action and consumer litigation.  Plaintiff has no interests that are contrary to, or in conflict with, members of the Class.   52.  A class action suit, such as the instant one, is superior to other available means for  fair and efficient adjudication of this lawsuit. The damages suffered by individual members of  the Class may be relatively small when compared to the expense and burden of litigation, making  it virtually impossible for members of the Class to.individually seek redress for the wrongs done  to them.   53.  A class action is, therefore, superior to other available methods for the fair and  efficient adjudication of the controversy. Further, absent these actions, members of the Class  likely will not obtain redress of their injuries, and Defendants will retain the proceeds of their  violations of the TCP A. In addition, Defendants are likely to continue to violate this statute.   54.  Furthermore, even if any member of the Class could afford individual litigation  against Defendants, it would be unduly burdensome to the judicial system. Concentrating this  litigation in one forum will promote judicial economy and parity among the claims of individual  members of the Class and provide for judicial consistency.   56.  Plaintiffs claims are typical of the claims of members of the Class. Plaintiff and  members of the Class have sustained damages arising out the same wrongful and uniform  practices of Defendants.   57.  Plaintiff knows of no difficulty that will be encountered in the management of this  litigation that would preclude its continued maintenance.  58.  Plaintiff hereby incorporates all facts and allegations of this document by  reference, as if fully set forth at length herein.   59.  At all times relevant hereto, Defendants used, controlled and or operated an  "automatic telephone dialing systems," as defined by 47 U.S.C. § 227(a)(l).   60.  Defendants initiated multiple telephone calls to Plaintiff and Class members'  cellular telephone lines using an automatic telephone dialing system.  See 47 U.S.C. §  227(b)(l)(A)(iii). These calls were made without the prior express consent by Plaintiff and Class  members to receive such calls.   62.  The acts and or omissions of Defendants were done willfully and knowingly,  absent bona fide error, lawful right, legal defense, justification, or legal excuse.   63.  In relevant part, the TCPA provides:  A person or entity may, if otherwise permitted by the laws or rules  of court of a State, bring in an appropriate court of that State- (A)  an action based on a violation of this subsection or the  regulations prescribed under this- subsection to enjoin such  violation,  (B)  an action to recover for actual monetary loss from such a  violation, or to receive $500.00 in damages for each such violation,  whichever is greater, or  (C)  both such actions.  If the court finds that the defendant willfully or knowingly violated  this subsection or the regulations prescribed under this subsection,  the court may, in its discretion, increase the amount of the award to  an amount equal to not more than 3 times the amount available  under subparagraph (B) of this paragraph.  47 u.s.c. § 227(b)(3).   64.  As a result of the above violations of the TCP A, Defendants are liable to Plaintiff  and the members of the Class in the sum of statutory damages, actual damages, and treble  damages.  Violation of the TCPA  