15.  Defendant provides commercial and personal property and casualty insurance,  personal accident and supplemental health insurance, reinsurance and life insurance to a diverse  group of clients.1  Unfortunately for consumers, Defendant utilized (and continues to utilize) a  sophisticated telephone dialing system to call individuals en masse promoting their services.   Defendant obtained these telephone numbers (i.e., leads) by purchasing marketing lists  containing consumers’ telephone numbers.   16.  In Defendant’s overzealous attempt to market their services, it placed (and  continues to place) phone calls to consumers who never provided consent to call and to  consumers having no relationship with Defendant. Worse yet, Defendant placed (and continues  to place) repeated and unwanted calls to consumers whose phone numbers are listed on the DNC.   Consumers place their phone numbers on the DNC for the express purpose of avoiding unwanted  telemarketing calls like those alleged here.   18.  Over eight years ago, on or about October 10, 2006, Plaintiff registered his  residential phone number ending in 3488 with the National Do Not Call Registry.   19.  On or around March 6, 2015 at 5:28 p.m., Plaintiff received a call on his  residential telephone from the phone number (855) 287-9329.   20.  On or around March 11, 2015 at 5:11 p.m., Plaintiff received a second call on his  residential telephone from the phone number (855) 287-9329.   21.  Plaintiff received both calls described above on his residential telephone assigned  a number ending in 3488.   22.  Although his number is registered on the DNC, Plaintiff receives a large volume  on telemarketing calls to his residential line.  Because the calls are intrusive and unwanted,  Plaintiff typically allows his answering system to pick up calls from numbers Plaintiff does not  recognize.     23.  Plaintiff did not recognize the telephone number above as each call was incoming.   Suspecting the caller was a telemarketer, Plaintiff allowed his answering system to pick up the  call.     24.  After the system prompted the caller to leave a message, the caller was silent  before Plaintiff heard clicks.  The caller ultimately disconnected the call without leaving a  message.     62.  Plaintiff re-alleges and incorporates by reference each preceding paragraph as  though set forth at length herein.   63.  47 U.S.C. § 227(c) provides that any “person who has received more than one  telephone call within any 12-month period by or on behalf of the same entity in violation of the  regulations prescribed under this subsection may” bring a private action based on a violation of  said regulations, which were promulgated to protect telephone subscribers’ privacy rights to  avoid receiving telephone solicitations to which they object.    64.  The TCPA’s implementing regulation—47 C.F.R. § 64.1200(c)—provides that  “[n]o person or entity shall initiate any telephone solicitation” to “[a] residential telephone  subscriber who has registered his or her telephone number on the national do-not-call registry of  persons who do not wish to receive telephone solicitations that is maintained by the federal  government.” See 47 C.F.R. § 64.1200(c).   A.  CLASS ALLEGATIONS   VIOLATION OF TCPA, 47 U.S.C. § 227  (“DNC Claim” On behalf of Plaintiff and the Class)  