14.  Plaintiff brings this action individually and on behalf of all others  similarly situated as a member of the proposed class concerning the ATDS claim  for no prior express consent (hereafter “The Class”) is defined as follows:  All persons within the United States who received any  solicitation/telemarketing telephone calls from Defendants  to said person’s cellular telephone made through the use of  any automatic telephone dialing system or an artificial or  prerecorded voice and such person had not previously  consented to receiving such calls within the four years prior  to the filing of this Complaint.   6.  On or around August 13, 2020, Defendants contacted Plaintiff on  Plaintiff’s cellular telephone numbers ending in -7447 to solicit Plaintiff to  purchase Defendants’ services.     Negligent Violations of the Telephone Consumer Protection Act  47 U.S.C. §227(b)  • As a result of Defendants’ negligent violations of 47 U.S.C.  §227(b)(1), Plaintiff and the ATDS Class members are entitled to and  request $500 in statutory damages, for each and every violation,  pursuant to 47 U.S.C.  227(b)(3)(B).   • Any and all other relief that the Court deems just and proper. 