22. Defendant NRA is a membership organization focused on firearms education, training, and advocacy.  23. The NRA has a sister organization, The NRA Foundation, which is a 501(c)(3) charitable organization, organized and existing under the laws of the District of Columbia.2  24. This is an important distinction, as the unsolicited telemarketing calls complained of herein were made on behalf of the NRA, not The NRA Foundation.  51. Plaintiff brings this action individually and on behalf of all other persons similarly situated (“Class Members”).  59. Plaintiff incorporates by reference the foregoing allegations as if fully set forth herein.  64. Plaintiff incorporates by reference the foregoing allegations as if fully set forth herein.  65. Defendants placed the telephone calls described in this complaint, which were telephone solicitations made for the purpose of encouraging Plaintiff and the other members of the Washington State Do Not Call Class to purchase Defendants goods and services, namely memberships in Defendant NRA, to Washington State.  66. Defendants placed unsolicited and unwanted calls to telephone numbers belonging to Plaintiff Kalmbach and other members of the Washington State Do Not Call Class within 12 months after the person had indicated to Defendants that s/he no longer wished to receive calls from Defendants.  67. Defendants and/or their agents have thus continually and repeatedly violated RCW  69. Plaintiff incorporates by reference the foregoing allegations as if fully set forth herein.  70. Pursuant to RCW 80.36.400(3), which provides that a violation of RCW 80.36.400 constitutes a violation of the Washington State Consumer Protection Act, RCW 19.86, et seq., Defendants and/or their agents have continually and repeatedly violated the WCPA by using ADADs to leave recorded messages for the purpose of encouraging Plaintiff Kalmbach and the Washington State Pre-recorded Call Class to purchase memberships in Defendant NRA.  71. The unsolicited telemarketing calls were made to Washington State.  72. As a direct result of Defendants’ conduct, Plaintiff Kalmbach and the other Washington State Pre-recorded Call Class members suffered damages, including $500 in statutory damages for each and every call in violation of the WADAD. The full amount of damages will be proven at trial. Plaintiff Kalmbach and the other members of the Washington State Pre-recorded Call Class are additionally entitled to treble damages, civil penalties, and costs and attorneys’ fees as provided by RCW 19.86.090.  A. General Factual Allegations  KATHARYN KALMBACH, individually and on behalf of all others similarly situated, Plaintiff v. Washington Automatic Dialing and Announcing Device Statute (Violations of RCW 80.36.400 et seq.) (On Behalf of Plaintiff and the Washington State Pre-Recorded Call Class)  Washington Do Not Call Statute (Violations of RCW 80.36.390 et seq.) (On Behalf of Plaintiff and the Washington State Do Not Call Class)  Washington Consumer Protection Act (Violation of RCW 19.86 et seq.) (On Behalf of Plaintiff and the Washington State Pre-recorded Call Class) 