14. Yet, Defendant kept making robocalls and subsequently settled two additional TCPA class actions, including another one in this District. See Gehrich v. Chase, No. 12-cv- 5510 (N.D. Ill. 2016) ($34 million TCPA class settlement); Connor v. Chase, No. 10 CV 01284 GPC BGS (S.D. Cal. Feb. 5, 2015) ($11,268,058 TCPA class settlement).  15. Despite at least three class settlements and numerous individual TCPA claims, Chase keeps making robocalls without consent.  16. Plaintiff is a natural person and citizen of the State of Indiana who resides in Michigan City, Indiana.  17. Plaintiff is the subscriber and regular user of the cellular telephone number at issue, (219) xxx-7061.  18. Thus, Plaintiff is the “called party” within the meaning of the TCPA. See Soppet v. Enhanced Recovery Co., LLC, 679 F.3d 637, 643 (7th Cir. 2012).  19. Defendant J.P. Morgan Bank, N.A. is a National Banking Association with its principal place of business at 270 Park Avenue, New York, New York 10017-2070.  20. In or around September 2019, Plaintiff began receiving numerous calls to her aforementioned cellular telephone number from Chase seeking to recover a debt relating to Robert Taschler, who was her deceased grandfather..  22. Plaintiff answered the September 17, 2019 call, which had a caller ID of (847) 488-2001.  There was a brief pause of dead air at the outset of the call, and the computer transferred Plaintiff to a Chase representative who asked for Robert Taschler.  Plaintiff advised the Chase representative that this was her phone and Chase was calling the wrong number.  23. On October 15, 2019, Chase again called Plaintiff’s cellular telephone number seeking to recover her deceased grandfather’s debt.  The caller ID for this call again displayed the number (847) 488-2001.  24. Plaintiff did not answer the October 15, 2019 call.  Instead, the caller left the following message in Plaintiff’s voicemail, which message began with a brief pause of dead air: [pause of dead air] Good afternoon, this message is for, uh, Robert Taschler.  My name is Casper.  I’m calling from Chase card services.  This is  regarding  an  important  matter  with  Chase.   It  is  not  a  sales  or solicitation call.  Please call us on (888) 293-5321, I repeat, it’s (888) 293- 5321, between 8:00 AM to midnight eastern standard time.  I really appreciate you listening to this message and I hope you have a lovely day. Thank you.  25. On October 15, 2019, Plaintiff returned Chase’s robocalls by calling (888) 293- 5321.  An artificial or prerecorded voice answered: “Thank you for calling Chase card services and returning our call.”  Plaintiff was then transferred to an artificial or prerecorded voice menu, which did not provide a way for Plaintiff to identify her number as a “wrong number” or opt out of further calls.  27. Yet, like clockwork, the following month on November 16, 2019, Chase placed yet another robo-call to Plaintiff’s cellular telephone number seeking to recover the same debt. The caller ID for this call displayed the number (847) 488-2001  28. On November 20, 2019, Chase placed another robo-call to Plaintiff’s cellular telephone number seeking to recover the same debt.  This time the caller ID changed to (847) 488-3078, which tricked Plaintiff into answering the unwanted call.  29. When Plaintiff answered the November 20, 2019 call, there was a brief pause of dead air at the outset of the call, and the computer transferred Plaintiff to a Chase representative who asked for Robert Taschler.  Plaintiff again advised the Chase representative that she had the wrong number, and the representative hung up.  30. Calls made to (847) 488-3078 are answered by an artificial or prerecorded voice stating: “Thank you for calling Chase card services.”  31. The  initial  pause  of  dead  air  at  the  start  of  the  October  15  voicemail  and  the November 20 call indicates that the calls were automatically initiated, without human intervention, from a machine that has the capacity to store or produce telephone numbers to be called and to dial such numbers.  33. During  the  aforementioned  phone  conversations  with  Defendant’s agents/representatives, Plaintiff expressly revoked any consent Defendant may have mistakenly believed it had to call Plaintiff’s aforementioned cellular telephone number using an ATDS.  34. Defendant made numerous calls to Plaintiff’s cellular telephone number, (219) xxx-7061, using an ATDS which has the capacity: to store or produce telephone numbers to be called, using a random or sequential number generator; and to dial such numbers, as defined by 47 U.S.C. § 227(a)(1).  35. Because the calls to Plaintiff did not start until after her grandfather passed away, and Plaintiff and her grandfather at one time resided at the same address, it appears Chase obtained Plaintiff’s cellular telephone from a third party skip-tracing service.  36. By effectuating these unlawful phone calls, Defendant caused Plaintiff the very harm that Congress sought to prevent—namely, a “nuisance and invasion of privacy.”  37. Defendant’s aggravating and annoying phone calls trespassed upon and interfered with Plaintiff’s rights and interests in her cellular telephone and cellular telephone line, and intruded upon Plaintiff’s seclusion.  38. Defendant’s phone calls harmed Plaintiff by wasting her time, trespassing on her phone, invading her privacy as well as causing aggravation and inconvenience.  39. Moreover,  “wireless  customers  [like  Plaintiff]  are  charged  for  incoming  calls whether they pay in advance or after the minutes are used.”  2008 FCC Ruling ¶ 7.  Defendant’s phone calls harmed Plaintiff by depleting the battery life on her cellular telephone, and by using minutes allocated to Plaintiff by her cellular telephone service provider.  41. None of Defendant’s telephone calls to Plaintiff’s cellular telephone number were for “emergency purposes” as specified in 47 U.S.C. § 227(b)(1)(A).  42. Defendant violated the TCPA with respect to the Plaintiff and members of the class.  43. Defendant willfully or knowingly violated the TCPA with respect to the Plaintiff and members of the class. 44. Plaintiff re-alleges and incorporates by reference the allegations contained in all other paragraphs as if fully stated herein.  Plaintiff, individually and on behalf of all others similarly situated, brings the above claims on behalf of a Class and numerous Subclasses.  46. Defendant has caused the Class and Subclasses actual harm, not only because they were subjected to the aggravation that necessarily accompanies these calls, but also because they frequently have to pay their cellphone service providers for the receipt of such calls.  47. These calls also intruded upon the Class and Subclass Members’ seclusion, trespassed on their telephones, diminish cellular battery life, and wasted their time.  48. Plaintiff represents and is a member of the Class and Subclasses.  Excluded from the Class and Subclasses is Defendant and any entities in which Defendant has a controlling interest, Defendant’s employees and agents, the Judge to whom this action is assigned, and any member of the Judge’s staff and immediate family.  49. Plaintiff is presently unaware of the exact number of members in each Class and Subclass, but based upon the size and scope of Defendant’s business, Plaintiff reasonably believes that the Class and Subclass members number, at a minimum, in the thousands.  50. Plaintiff and all members of each Class and Subclass have been harmed by Defendant’s actions.  51. This Class Action Complaint seeks money damages and injunctive relief.  52. The joinder of all Class and Subclass members is impractical due to the size and relatively modest value of each individual claim.  54. There are question of law and fact common to the members of each Class and Subclass, which common questions predominate over any questions that affect only individual class members.  Those common questions of law and fact include, but are not limited to: a) Whether the system used to place the calls was an ATDS; b) Whether Defendant engaged in a pattern of using an ATDS to place calls to cellular telephone numbers without the prior express consent of the called party; c) Whether someone advising Defendant to cease contact revokes any prior express consent to call that may have previously existed; d) Whether someone advising Defendant it is calling the wrong number revokes any prior express consent to call even if it is not a true wrong number; e) Whether Defendant’s conduct was willful or knowing; and f) Whether Defendant’s actions violated the TCPA.  55. As a person who received calls that were made using an ATDS without prior express consent, all within the meaning of the TCPA, Plaintiff asserts claims that are typical of the members of each Class and Subclass.  56. Plaintiff will fairly and adequately represent and protect the interests of the Class and each Subclass, and Plaintiff does not have an interest that is antagonistic to any member of any Class or Subclass.  57. Plaintiff has retained counsel experienced in handling class action claims involving violations of federal and state consumer protection statutes such as the TCPA.  59. Class-wide relief is essential to compel Defendant to comply with the TCPA.  The interest of class members in individually controlling the prosecution of separate claims against Defendant is small because the statutory damages in an individual action for violation of the TCPA are small.  60. Management of these claims as a class action is likely to present significantly fewer difficulties than are presented by many class claims because the calls at issue are all automated and the Class and Subclass members, by definition, did not provide the prior express consent required under the statute to authorize calls to their cellular telephones.  61. Defendant has acted on grounds generally applicable to each Class and Subclass, thereby making final injunctive relief and corresponding declaratory relief with respect to each Class and Subclass as a whole appropriate.  62. Moreover, the TCPA violations complained of herein are substantially likely to continue in the future if an injunction is not entered. 63. Plaintiff re-alleges and incorporates by reference the allegations contained in paragraphs 1 through 61.  64. Defendant violated the TCPA with respect to Plaintiff each time Defendant or someone acting on its behalf called Plaintiff’s cellular telephone number using an ATDS without having prior express consent.  66. Defendant knowingly violated the TCPA for each call to a number after consent was revoked.  67. Defendant repeatedly placed non-emergency telephone calls to Plaintiff’s cellular telephone number using an ATDS without Plaintiff’s prior express consent, in violation of federal law including 47 U.S.C. § 227(b)(1)(A)(iii).  68. As a result of Defendant’s illegal conduct, Plaintiff and the members of the class suffered actual damages and, under 47 U.S.C. § 227(b)(3)(B), are entitled to, inter alia,  a minimum of $500.00 in damages for each such violation of the TCPA.  Violation of the TCPA 