15.  Circle K runs a rewards program called “Easy Rewards” to incentive  consumers to shop at Circle K, for which it sends unsolicited sign up text messages  to consumers.   23.  Plaintiff brings this action pursuant to Federal Rule of Civil Procedure  23(b)(2) and Rule 23(b)(3) on behalf of himself and all others similarly situated  and seeks certification of the following Class:  All persons in the United States who from four years prior  to the filing of this action through class certification (1) Defendant (or  an agent acting on behalf of Defendant) text messaged, (2) on the  person’s cellular telephone number, (3) using a text messaging platform  substantially similar to the text messaging platform Defendant used to  text message Plaintiff, (4) for whom Defendant claims (a) it obtained  prior express consent in the same manner as Defendant claims it  supposedly obtained prior express consent to text message Plaintiff, or  (b) it did not obtain prior express consent.   29.  Plaintiff repeats and realleges paragraphs 1 through 28 of this  Complaint and incorporates them by reference.   30.  Defendant and/or its agents sent unwanted solicitation text messages  to cellular telephone numbers belonging to Plaintiff and the other members of the  Autodialed No Consent Class using an autodialer.    31.  These solicitation text messages were sent en masse without the  consent of the Plaintiff and the other members of the Class to receive such  solicitation text messages.   32.  Defendant’s conduct was negligent, wilful, or knowing.   33.  Defendant has, therefore, violated 47 U.S.C. § 227(b)(1)(A)(iii). As a  result of Defendant’s conduct, Plaintiff and the other members of the Class are  each entitled to between $500 and $1,500 for each and every text message.  Circle K Sends Unsolicited Text Messages Using an Autodialer    Class Treatment Is Appropriate for Plaintiff’s TCPA Claim   Telephone Consumer Protection Act  (Violations of 47 U.S.C. § 227)  (On Behalf of Plaintiff and the Class)  