(Violation of 47 U.S.C. § 227, et seq. – Telephone Consumer Protection Act)  (on behalf of Plaintiff and the Class)   31.  Plaintiff incorporates the foregoing allegations as if fully set forth herein.   32.  In an effort to obtain clients, Casting360 made unsolicited and unwanted text  message calls to Plaintiff and the Class's cellular telephones without their prior express consent.   33.  Casting360 sent the promotional text messages to Plaintiff and the Class's  cellular telephone numbers using equipment that had the capacity to store or produce telephone  numbers to be called using a random or sequential number generator, and/or receive and store  lists of phone numbers, and to dial such numbers en masse.   34.  Casting360 utilized equipment that sent the promotional text messages to  Plaintiff and other members of the putative Class simultaneously and without human  intervention.   35.  By sending the promotional text messages to Plaintiffs and members of the  Class's cellular telephones without prior express consent, and by utilizing an ATDS, Casting360  violated 47 U.S.C. § 227(b)(I)(A)(iii).   36.  As a result of Casting360's unlawful conduct, Plaintiff and the members of the  putative Class suffered actual damages and have also had their rights to privacy adversely  impacted. Plaintiff and the Class are therefore entitled to, among other things, a minimum of  $500 in statutory damages for each such violation under 47 U.S.C. § 227(b)(3)(B).  