 Knowing and/or Willful Violation of the Telephone Consumer Protection Act (47 U.S.C.  227, et seq.) on behalf of all Classes and Subclasses as to all Defendants    Statutory Violations of the Telephone Consumer Protection Act (47 U.S.C. 227, et seq.)   on behalf of all Classes and Subclasses as to all Defendants.   25.  Defendant Sunrise Communications, Inc. is, and at all times mentioned herein  was, a “person,” as defined by 47 U.S.C. § 153(39).   26.  Defendant AT&T, Inc. is, and at all times mentioned herein was, a “person” as  defined by 47 U.S.C. § 153(39).   27.  Sunrise describes itself on its website5 as having “working relationships with the  phone, cable, and mobility companies. We provide the following services for our carrier  partners: inbound and outbound call center services, traditional and digital marketing, and  channel sub-agent partner sales.”  Among its customers are “AT&T, Verizon, Century Link,  Time Warner Cable, Charter, Comcast, Mediacom, and DirecTV to name a few.”   39.  Plaintiff incorporates by reference all other paragraphs of this Complaint as if  fully stated herein.   41.  Plaintiff proposes the following Class and Subclass definitions, subject to  amendment as appropriate:   (i) The Class: All persons in the United States and its Territories who, within four years  prior to the commencement of this litigation, received one or more texts on their cellular  telephone advertising the sale of services provided by AT&T, sent via an automated telephone  dialing system without providing prior express written consent to receive such texts.  (ii) The Sunrise Subclass: All persons in the United States and its Territories who, within  four years prior to the commencement of this litigation, received one or more texts on their  cellular telephone advertising the sale of AT&T products or services to be provided by or  through Sunrise Communications, sent via an automated telephone dialing system without  providing prior written express consent to receive such texts.   42.  Plaintiff Wieseler-Myers is a member of, and will fairly and adequately represent  and protect the interests of, the Class and Subclass.     43.  Excluded from the Class and Subclass are Defendants, any entities in which  Defendants have a controlling interest, Defendants’ 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.   44.  Plaintiff does not know the exact number of members in the Class and Subclass,  but Plaintiff reasonably believes Class members number, at minimum, in the thousands in each  class and subclass.   46.  This Class Action Complaint seeks injunctive relief and money damages.   47.  The joinder of all Class members is impracticable due to the size and relatively  modest value of each individual claim.   48.  Additionally, the disposition of the claims in a class action will provide  substantial benefit to the parties and the Court in avoiding a multiplicity of identical suits.   49.  Further, all members of the Classes and Subclasses can be identified through  records maintained by Defendants and/or their telemarketing agents and/or telephone carriers.   50.  There are well defined, nearly identical, questions of law and fact affecting all  parties.   51.  The questions of law and fact, referred to above, involving the class claims  predominate over questions which may affect individual Class and Subclass members.   53.  As a person who received non-emergency texts on her cellular telephone using an  automatic telephone dialing system without her prior express written consent within the meaning  of the TCPA, Plaintiff asserts claims that are typical of each Class member who also received  such texts.   54.  Further, Plaintiff will fairly and adequately represent and protect the interests of  the Class.  Plaintiff has no interests which are antagonistic to any member of the Class.   55.  Plaintiff has retained counsel with substantial experience in prosecuting complex  litigation and class actions.  Plaintiff and her counsel are committed to vigorously prosecuting  this action on behalf of the other members of the Class, and have the financial resources to do so.     56.  Absent a class action, most members of the Class would find the cost of litigating  their claims to be prohibitive and would have no effective remedy.  The class treatment of  common questions of law and fact is also superior to multiple individual actions or piecemeal  litigation in that it conserves the resources of the courts and the litigants, and promotes  consistency and efficiency of adjudication.  58.  The foregoing acts and omissions of the Defendants 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.   59.  As a result of the Defendants’ violations of 47 U.S.C. §  227 et seq., Plaintiff and  Class members are entitled to an award of $500 in statutory damages for each and every  violation of the statute, pursuant to 47 U.S.C. § 227(b)(3)(B).   60.  Plaintiff and Class members are also entitled to and do seek injunctive relief  prohibiting the Defendants’ violation of the TCPA in the future.  61.  Plaintiff incorporates by reference the foregoing allegations as if fully set forth  herein.   62.  The foregoing acts and omissions of the Defendants 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.   63.  As a result of the Defendants’ knowing and/or willful violations of 47 U.S.C. §   227 et seq., Plaintiff and each member of the Class is entitled to treble damages of up to $1,500  for each and every violation of the statute, pursuant to 47 U.S.C. § 227(b)(3).   Sunrise Communications and AT&T  