44. Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   48. Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   49. The foregoing acts and omissions of Defendants constitute numerous  and multiple knowing and/or willful violations of the TCPA, including but not  limited to each and every one of the above-cited provisions of 47 U.S.C. § 227 et  seq.   I, Dante Pride, hereby certify that, according to the computer program used to  prepare this document, Complaint, contains 4658 words.  I declare under penalty of perjury under the laws of the State of California that  the foregoing is true and correct.  Executed on this 30th day of January, 2017, in San  Diego, California.    /s/ Dante T. Pride  Dante T. Pride  Attorney for Plaintiff  KNOWING AND/OR WILLFUL VIOLATIONS OF THE  TELEPHONE CONSUMER PROTECTION ACT (TCPA)  47 U.S.C. 227   NEGLIGENT VIOLATIONS OF THE   TELEPHONE CONSUMER PROTECTION ACT (TCPA)  47 U.S.C. 227   THE (TCPA), 47 U.S.C. 227 ET. SEQ.   As a result of Defendants negligent violations of 47 U.S.C. § 227(b)(1),  Plaintiff seeks for himself and each Class member $500.00 in statutory  damages, for each and every violation, pursuant to 47 U.S.C. §  227(b)(3)(B).   Pursuant to 47 U.S.C. § 227(b)(3)(A), injunctive relief prohibiting such  conduct in the future.   Any other relief the Court may deem just and proper. 