12.  At all times relevant, Plaintiff is, and at all times mentioned herein was, a  “person” as defined by 47 U.S.C. § 153(39).     13.  On or about October 24, 2014, Plaintiff was involved in an automobile  accident with another individual.  This other individual was insured by Mercury Insurance Group  (hereafter “Mercury”) at the time of the accident.   14.  Plaintiff was insured by GEICO at the time of the accident.  However, on  information and belief, Mercury and/or CRS wrongly concluded that Plaintiff was uninsured.   15.  Upon information and belief, CRS received a file from Mercury  containing Plaintiff’s cellular telephone number.  On the same day it received the file, it entered  Plaintiff’s cellular telephone number into an automated telephone dialing system” (“ATDS”).     26.  Plaintiff brings this action on behalf of himself and on behalf of all other  persons similarly situated (hereinafter referred to as “the Class”).   27.  Plaintiff proposes the following Class definition, subject to amendment  as appropriate:  All persons within the United States who, on or after April 22, 2012, received a  non-emergency telephone call from CRS to a cellular telephone through the use of  an automatic telephone dialing system or an artificial or prerecorded voice, and  who did not have a contractual relationship with the company on whose behalf  CRS made the call.  Collectively, all these persons will be referred to as “Class members.”  Plaintiff represents, and is  a member of, the Class.  Excluded from the Class are CRS and any entities in which CRS has a  controlling interest; CRS’s agents and employees; any Judge to whom this action is assigned and  any member of such Judge’s staff and immediate family; and claims for personal injury, wrongful  death and/or emotional distress.                       28.    Plaintiff also proposes three Subclasses.  Subclass One consists of all  Class members who residents of California (hereafter “the California Subclass”).  Plaintiff  represents, and is a member of, the California Subclass.  In this Complaint, all references to “the  Class” apply likewise to the California Subclass, unless otherwise specified.   44.  Plaintiff incorporates by reference the foregoing paragraphs of this  Complaint as if fully set forth herein.   45.  The foregoing acts and omissions of CRS constitute numerous and  multiple violations of the TCPA, including but not limited to each of the above cited provisions of  47 U.S.C. § 227 et seq.    46.  As a result of CRS’s violations of 47 U.S.C. § 227 et seq., Plaintiff and  Class members are entitled to an award of $500.00 in statutory damages for each and every  violation of the statute, pursuant to 47 U.S.C. § 227(b)(3)(B).     47.  Plaintiff and Class members are also entitled to and do seek injunctive  relief prohibiting CRS’s violation of the TCPA in the future.   49.  Plaintiff incorporates by reference the foregoing paragraphs of this Complaint as if  fully set forth herein.   50.  CRS’s practice of making telephone calls to Plaintiff and members of the Subclass  on their cellular telephones via an “automatic telephone dialing system” without their prior  express consent within the meaning of the TCPA violates 47 U.S.C. § 227 et seq., and the Rules  promulgated thereunder.   51.  CRS’s conduct described herein violates Cal. Bus & Prof. Code § 17200 et seq.  (the “UCL”) in the following respects:  a.  CRS’s utilization of automated and predictive dialing techniques to harass  Plaintiff and members of the Class is unlawful and a violation of the UCL.  b.  CRS’s use of automated and predictive dialing techniques to harass  Plaintiff and members of the Class is unlawful and a violation of the UCL.  c.  Each of CRS’s violations of the TCPA and Rules constitute a separate and  independent violation of the UCL because such conduct was illegal and unfair competition within  the meaning of the UCL.   52.  The harm to Plaintiff and the Subclass arising from CRS’s illegal practices  outweighs the utility, if any, of those practices.   53.  The illegal business practices of CRS are immoral, unethical, oppressive,  unscrupulous, and/or substantially injurious to Plaintiff and members of the Class.   54.  Unless restrained by this Court, CRS will continue to engage in the illegal acts and  practices alleged above.   CALIFORNIA MERCURY SUBCLASS ONLY  VIOLATIONS OF CALIFORNIA’S UNFAIR COMPETITION LAW, CAL. BUS. &  PROF. CODE SECTION 17200, ET SEQ.   KNOWING AND/OR WILLFUL VIOLATIONS OF THE TELEPHONE  CONSUMER PROTECTION ACT, 47 U.S.C. § 227 ET SEQ.   VIOLATIONS OF THE TELEPHONE CONSUMER PROTECTION ACT 47 U.S.C. § 227  ET SEQ.  