10. Upon information and belief, on or about February 7, 2018 Defendants, without Plaintiff’s  express invitation or permission, arranged for and/or caused a telephone facsimile  machine, computer, or other device to send unsolicited fax advertisements (hereinafter  “the fax advertisements”), advertising the commercial availability or quality of any  property, goods, or services, to Plaintiff’s fax machine located in New Jersey.     11. Copies of the fax advertisement are attached hereto as Exhibit A and are incorporated  herein by reference.   12. Upon receiving the Defendant’s fax, the Plaintiff’s fax machine was occupied during the  time that the incoming fax was being processed.   13. Further, upon receiving the Defendant’s fax, the Plaintiff’s fax machine automatically  printed out the fax, thereby depleting the Plaintiff’s ink, toner and paper.    14. The fax advertisement attached hereto as Exhibit A was wholly unsolicited in that it was  sent to the Plaintiff by Defendants without Plaintiff’s express invitation or permission.   Plaintiff does not currently do business with Defendant, and has never done business with  Defendant.     15. Upon information and belief, Defendants either negligently, willfully and/or knowingly  arranged for and/or caused the fax advertisements to be sent to Plaintiff’s fax machine.   20. Plaintiff brings this action individually and on behalf of and all others similarly situated  (“the Class”).   22. Defendant and its employees or agents are excluded from the Class.  Plaintiff does not  know the number of members in the Class, but believe 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 this matter.   23. Plaintiff and members of the Class were harmed by the acts of Defendant in at least the  following ways: Defendant, either directly or through its agents, illegally contacted  Plaintiff and the Class members via their telephone facsimile machines by either: 1)  sending unsolicited fax advertisements; or 2) sending fax advertisements which failed to  properly inform Plaintiff and the class members of their ability to opt-out of receiving  such fax advertisements from Defendant in the future.  Plaintiffs and the Class members  were damaged thereby.   24. This suit seeks only damages and injunctive relief for recovery of economic injury on  behalf of the Class, and it expressly is not intended to request any recovery for personal  injury and claims related thereto.  Plaintiff reserves the right to expand the Class definition  to seek recovery on behalf of additional persons as warranted as facts are learned in further  investigation and discovery.   25. The joinder of the Class members is impractical and the disposition of their claims in the  Class action will provide substantial benefits both to the parties and to the court.  The  Class can be identified through Defendant’s records or Defendant’s agents’ records.   27. As a recipient of unsolicited fax advertisements from Defendant and of fax advertisements  which failed to properly advise of Plaintiff’s ability to opt-out, Plaintiff is asserting claims  that are typical of the Class.  Plaintiff will fairly and adequately represent and protect the  interests of the Classes in that Plaintiff has no interests antagonistic to any member of the  Classes.   28. Plaintiff and members of the Classes were harmed by the acts of Defendant in at least the  following ways: Defendant, either directly or through its agents, illegally contacted  Plaintiff and the Class members via their telephone facsimile machines by sending  unsolicited fax advertisements;    29. Plaintiffs and the Class members were damaged thereby.   31. Plaintiff and the members of the Class have all suffered irreparable harm as a result of the  Defendant’s unlawful and wrongful conduct.  Absent a class action, the Class will  continue to face the potential for irreparable harm.  In addition, these violations of law  will be allowed to proceed without remedy and Defendant will likely continue such illegal  conduct.  Because of the size of the individual Class member’s claims, few, if any, Class  members could afford to seek legal redress for the wrongs complained of herein.   32. Plaintiff has retained counsel experienced in handling class action claims and claims  involving violations of the Telephone Consumer Protection Act.   33. A class action is a superior method for the fair and efficient adjudication of this  controversy.  Class-wide damages are essential to induce Defendant to comply with  federal and state laws.  The interest of Class members in individually controlling the  prosecution of separate claims against Defendant is small because the maximum statutory  damages in an individual action for violation of privacy are minimal.  Management of  these claims is likely to present significantly fewer difficulties than those presented in  many class claims.    34. Defendant has acted on grounds generally applicable to the Classes, thereby making  appropriate final injunctive relief and corresponding declaratory relief with respect to the  Class as a whole.  36. At all times herein, Plaintiff was and is entitled to the rights, protections and benefits  provided under the Telephone Consumer Protection Act, 47 U.S.C. § 227.    37. The transmission of facsimiles to Plaintiff as set forth above, violated 47 U.S.C. §  227(b)(1)(C).    38. Based upon the foregoing, Plaintiff is entitled to statutory damages pursuant to 47 U.S.C.  § 227(b)(3)(B) and 227(b)(3)(C).   39. Based upon the foregoing, Plaintiff is entitled to an Order, pursuant to 47 U.S.C. §  227(b)(3)(A), enjoining Defendant from transmitting any advertisements in violation of  47 U.S.C. § 227(b)(1)(C).  40. Defendants committed violations of N.J.S.A. § 56:8-158(a) against Plaintiff and the  members of Class B by sending unsolicited fax advertisements to Plaintiff and the  members of Class B.   41.  Based upon the foregoing, Plaintiff is entitled to statutory damages pursuant to N.J.S.A.  § 56:8-159.  VIOLATIONS OF NEW JERSEY CONSUMER FRAUD ACT   Violations of the Telephone Consumer Protection Act, 47 U.S.C. § 227  