10. Neither Leyse nor the other Class Members had given Lifetime prior express invitation or permission to place a Lifetime Robocall to them.  12. Plaintiff repeats and realleges each and every allegation contained in paragraphs “1” through “11” inclusive of this Complaint as if fully set forth herein.  13.  The placement of the Lifetime Robocalls to Plaintiff and Members of the Class violated 47 U.S.C. § 227(b)(1)(B) and 47 C.F.R. § 64.1200(a)(2).  14.  Based upon the foregoing, Plaintiff and Members of the Class are entitled to statutory damages pursuant to 47 U.S.C. §§ 227(b)(3)(B) and 227(b)(3)(C).  15.  Based upon the foregoing, Plaintiff and Members of the Class are entitled to an Order, pursuant to 47 U.S.C. § 227(b)(3)(A), enjoining Defendant from violating 47 U.S.C. § 227(b)(1)(B) and 47 C.F.R. § 64.1200(a)(2). 16.  Plaintiff brings this action as a Class Action pursuant to Federal Rules of Civil Procedure 23(a) and 23(b)(3) individually and as a class action on behalf of all persons to whose residential telephone lines Lifetime, or a third party acting on behalf of Lifetime, placed one or more telephone calls using an artificial or prerecorded voice that delivered a message that advertised the commercial availability or quality of property, goods, or services, other than Defendant, its officers, employees, representatives, and their families (the “Class”), during the period from August 17, 2009, to the commencement of this action until the present (the “Class Period”).  17.  The Members of the Class are so numerous that joinder of all Members is impracticable.  19.  Plaintiff will fairly and adequately protect the interests of the Class. Plaintiff has retained competent litigation counsel. Plaintiff has no interests that are antagonistic to, or in conflict with, the Members of the Class. Indeed, Plaintiff’s interests are, for purposes of this litigation, coincident with the interests of the other Class Members.  20.  A class action is superior to all other available methods for the fair and efficient adjudication of this controversy. Because the Class is so numerous that joinder of all Members is impracticable, and because the damages suffered by most of the individual Members of the Class are too small to render prosecution of the claims asserted herein economically feasible on an individual basis, the expense and burden of individual litigation makes it impractical for Members of the Class to adequately address the wrongs complained of herein. Plaintiff knows of no impediments to the effective management of this action as a class action.  7. On or about August 19, 2009, Lifetime, or a third party acting on behalf of Lifetime, placed, to Leyse’s residential telephone line, a telephone call using an artificial or prerecorded voice that delivered a message (“Message”) that advertised the commercial availability and quality of Lifetime Television, a cable-television network that Lifetime owns and operates (a “Lifetime Robocall”).  8. As the result of the placement of the Lifetime Robocall, Leyse: (i) was deprived of his substantive right not to have a Lifetime Robocall placed to his telephone line; (ii) was deprived of the use of his telephone line; (iii) lost his valuable time in listening to the Message; (iv) endured a nuisance; (v) endured an invasion of his privacy; (vi) endured an intrusion upon his seclusion; and (vii) endured a disturbance of his solitude.  9. During the Class Period, Lifetime, or one or more third parties acting on behalf of Lifetime has placed, to thousands of residential telephone lines, telephone calls using an artificial or prerecorded voice that delivered a message that advertised the commercial availability or quality of one of the cable-television networks that Lifetime owns and operates. 