11. In fact, Plaintiff regularly receives unsolicited marketing texts from Defendant notwithstanding Plaintiff's repeated requests that Defendant stop texting her.  12. For example, on February 14, 2020 at 6:57 am, Defendant sent an unsolicited text message to Plaintiff from short code 71203.  Plaintiff responded to the text message less than an hour later by texting "STOP."  Notwithstanding, Defendant sent Plaintiff another unsolicited text message the same day, only a few hours later, at 10:49 am:  13. Plaintiff has never provided her consent to Too Faced Cosmetics to send her text messages to her cellular phone number using an automatic telephone dialing system, and even if she had, she subsequently revoked such consent by texting "STOP" in response to many of Defendant's text messages .  14. Defendant's unsolicited texts were a nuisance that aggravated Plaintiff, wasted her time, invaded her privacy, diminished the value of the cellular services she paid for, caused her to temporarily lose the use and enjoyment of her phone, and caused wear and tear to her phone's data, memory, software, hardware, and battery components.  16. On information and belief, Too Faced Cosmetics, or a third-party acting on its behalf, sent substantively identical unsolicited text messages en masse to the cellular telephone numbers of thousands of consumers.  This is evident from the text messages' commercial and generic content, that the text messages were unsolicited, and that they were using an automatic telephone dialing system.  17. To the extent the text messages were sent on Defendant's behalf to consumers, Defendant provided the third-party access to its records, authorized use of its trade name and devoted short code, otherwise controlled the content of the messages, and knew of, but failed to stop, the sending of the text messages in violation of the 26. Plaintiff repeats and realleges the allegations of paragraphs 1 through 25 of this complaint and incorporates them by reference.  27. Defendant and/or its agents transmitted text messages to cellular telephone numbers belonging to Plaintiff and the other members of the ATDS Class using an automatic telephone dialing system.  28. These solicitation text messages were sent without the consent of Plaintiff and the other members of the ATDS Class.  29. Defendant has, therefore, violated 47 U.S.C. § 227(b)(1)(A)(iii), and as a result, under 47 U.S.C. §§ 227(b)(3)(B)-(C), Plaintiff and members of the ATDS Class are entitled to a minimum of $500 and a maximum $1,500 in damages for each violation.  8. Defendant is a  cosmetics company.  9. To increase sales of Too Faced Cosmetics products and services, and as part of a general marketing scheme, Defendant markets its brand using text messages to consumers.   Violation of 47 U.S.C. § 227 (On Behalf of Plaintiff and the ATDS Class) 