10.  In the last four years, United began placing automated telephone calls to Plaintiff  on her cellular telephone at telephone number XXX-XXX-5758 regarding the Loan.   11.  United called Plaintiff from telephone numbers 646-783-4330, 800-833-1940,  646-783-4319, and 646-462-4902.   12.  At all times mentioned herein, Defendant called Plaintiff’s cellular telephone  using an “automatic telephone dialing system” (“autodialer”) as defined by 47 U.S.C. §  227(a)(1).   13.  When Plaintiff answered the calls from United, she heard a prerecorded voice  message asking Plaintiff to “please hold” for the next available representative.  After the  message the calls would be routed to a live agent.  When Plaintiff did not answer the calls,  United left blended prerecorded/automated voice messages in her voice-mailbox stating: “This is  an important message for Isaiah Evans.  Please have Isaiah Evans call United Auto Credit at . . .  .”  This is indicative of United’s use of a “predictive dialer,” an autodialer under the TCPA.   14.  Plaintiff does not owe a debt to United.  Plaintiff has never done business with  United.  Plaintiff did not give her number to United or permit Isaiah Evans to do so.  Plaintiff  did not provide prior express consent to United to autodial her cellular telephone.  Accordingly,  the automated calls placed by Defendant to Plaintiff were in violation of 47 U.S.C. §  227(b)(1)(A).   16.  Nonetheless, United continued to place automated, prerecorded voice calls to  Plaintiff’s cell phone.   17.  Plaintiff was annoyed, frustrated, and inconvenienced by United’s calls.   United’s calls often distracted Plaintiff from her work or from caring for her children.  United  called from several different numbers and Plaintiff was unable to successfully screen the calls.   18.  The telephone number called by Defendant was and is assigned to a cellular  telephone service for which Plaintiff incurs charges for incoming calls pursuant to 47 U.S.C. §  227(b)(1).   19.  The calls from Defendant to Plaintiff were not placed for “emergency purposes”  as defined by 47 U.S.C. § 227(b)(1)(A)(i).  20.  Plaintiff brings this claim pursuant to Federal Rule of Civil Procedure 23(b)(2)  and (b)(3) on behalf the following classes (the “Classes”):   TCPA Class: (1) All persons in the United States (2) to whose cellular  telephone number (3) United placed a non-emergency telephone call (4) using  an autodialer or a prerecorded voice (5) within four years of the complaint  (6) where United did not have express consent to call said cellular telephone  number.  Willful/Knowing Violation Class: (1) All persons in the United States (2) to  whose cellular telephone number (3) United placed a non-emergency  telephone call (4) using an autodialer or a prerecorded voice (5) within four  years of the complaint (6) after said person had advised United to cease  calling.   22.  Plaintiff does not know the exact number of members in the Classes, but based  upon the size and national scope of United and the automated nature of the calls, Plaintiff  reasonably believes that the Classes number in the thousands.   23.  The joinder of all Class members is impracticable due to the size and relatively  modest value of each individual claim. 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. The Class can be identified easily through records maintained by Defendant.   24.  There are questions of law and fact common to the members of the Class which  predominate over any questions that affect only individual Class members. Those common  questions of law and fact include, but are not limited to, the following:  i.  Whether United engaged in a pattern of using an autodialer to place calls  to cellular phones;   ii.  Whether United had prior express consent to place the calls; and  iii.  Whether United willfully violated the TCPA.   25.  As a person who received automated telephone calls from United on her cellular  phone without having given prior express consent, and who advised United to cease calling,  Plaintiff asserts claims that are typical of the members of the Classes.  Plaintiff will fairly and  adequately represent and protect the interests of the class, and has no interests which are  antagonistic to any member of the Classes.   27.  A class action is the superior method for the fair and efficient adjudication of this  controversy.  Class-wide relief is essential to compel Defendant to comply with the TCPA.   The interest of individual Class members in individually controlling the prosecution of separate  claims against Defendant is small because the statutory damages for violation of the TCPA are  small in comparison to the costs and expenses of litigation of such claims.  Management of  these claims is likely to present few difficulties because the calls at issue are all automated and  the Class members, by definition, did not provide the prior express consent required under the  statute to authorize calls to their cellular telephones as United did not attempt to obtain consent  required by the TCPA prior to placing the calls.   28.  Defendant has acted on grounds generally applicable to the Classes, thereby  making final injunctive relief and corresponding declaratory relief with respect to the Class  appropriate. Moreover, Plaintiff alleges that the TCPA violations complained of herein are  substantially likely to continue in the future if an injunction is not entered.  29.  Plaintiff incorporates the foregoing allegations as if fully set forth herein.     30.  Plaintiff brings this claim on behalf of herself and the Classes.   31.  United made automated telephone calls to the wireless telephone number of  Plaintiff and the other Class members. These phone calls were made without the prior express  consent of Plaintiff or the other Class members and were not made for emergency purposes.   33.  Each of the aforementioned calls by United constitutes a violation of the TCPA.     34.  Plaintiff and Class members are entitled to an award of $500.00 in statutory  damages for each call made in violation of the TCPA pursuant to 47 U.S.C. § 227(b)(3)(B).   35.  Plaintiff and Class members are also entitled to and do seek injunctive relief  prohibiting Defendant’s violation of the TCPA in the future.   36.  Plaintiff and Class members are also entitled to and do seek a declaration that:  • Defendant violated the TCPA;  • Defendant used an autodialer; and  • Defendant placed calls to the Plaintiff and the Class without prior express  consent.  37.  Plaintiff incorporates the foregoing allegations as if fully set forth herein.     38.  Plaintiff brings this claim on behalf of herself and the Class.   39.  United made automated telephone calls to the wireless telephone number of  Plaintiff and the other Class members. These phone calls were made without the prior express  consent of Plaintiff or the other Class members and were not made for emergency purposes.   40.  United has therefore violated the TCPA, 47 U.S.C. § 227(b)(1)(A), which makes  it “unlawful for any person within the United States . . . to make any call (other than a call made  for emergency purposes or made with the prior express consent of the called party) using any  automatic telephone dialing system or an artificial or prerecorded voice.”   41.  Each of the aforementioned calls by United constitutes a willful violation of the  9.  Plaintiff’s acquaintance “Isaiah Evans” obtained an auto loan from United (the  “Loan”).  Plaintiff was not a debtor or co-signer on the Loan.  