39.  Plaintiff Canary is, and at all times mentioned herein was, a “person” as defined by  Plaintiff Canary   STATUTORY VIOLATIONS OF THE TELEPHONE CONSUMER PROTECTION ACT  47 U.S.C. §  227 ET SEQ.  128.  Plaintiff incorporates by reference the foregoing paragraphs of this Complaint as if  fully set forth herein.  129.  The foregoing acts and omissions of Defendant constitute numerous and multiple  violations of the TCPA, including but not limited to each of the above cited provisions of  47 U.S.C. § 227 et seq.   130.  As a result of Defendant’s violations of 47 U.S.C. § 227 et seq., Plaintiff and Class  Members are entitled to an award of $500 in statutory damages for each and every call in violation  of the statute, pursuant to 47 U.S.C. § 227(b)(3)(B).    131.  Plaintiff and Class Members are also entitled to and do seek injunctive relief  prohibiting the Defendant’s violation of the TCPA in the future.  132.  Plaintiff and Class Members are also entitled to an award of attorneys’ fees and  costs as provided by law.  