15.  At all times relevant, Plaintiff was a citizen of the State of California.   Plaintiff is, and at all times mentioned herein was, a “person” as defined by 47  35.  Plaintiff incorporates the foregoing allegations as if fully set forth  herein.   36.  The foregoing acts and omissions of Defendant constitute numerous  and multiple negligent violations of the TCPA.    37.  As a result of Defendant’s negligent violations of the TCPA, Plaintiff  and the Class are entitled to an award of $500.00 in statutory damages, for each and  every violation, pursuant to 47 U.S.C. Section 227(b)(3)(B).      38.  Plaintiff and the Class are entitled to and seek injunctive relief  prohibiting such conduct in the future.     39.  Additionally, as a result of Defendant’s unlawful conduct, Plaintiff and  the other members of the Class are entitled to an injunction under 47 U.S.C. §  227(b)(3)(A) to ensure that Defendant’s violations of the TCPA do not continue into  the future.   40.  Plaintiff and the Class are entitled to an award of attorneys’ fees and  costs.   41.  Plaintiff incorporates the allegations in Paragraphs 1 - 34 as if fully set  forth herein.    42.  The foregoing acts and omissions of Defendant constitute numerous  and multiple knowing and/or willful violations of the TCPA.    Negligent Violation of 47 U.S.C. § 227 et seq.  (On behalf of Plaintiff and the Class)   Willful Violation of 47 U.S.C. § 227 et seq.  (On behalf of Plaintiff and the Class)  