10.  Defendant contacted or attempted to contact Plaintiff from telephone  numbers (813) 295-2840, (646) 813-2670, and (617) 581-0895, confirmed to  belong to Defendant.   11.  Defendant’s calls constituted calls that were not for emergency  purposes as defined by 47 U.S.C. § 227(b)(1)(A).   12.  Defendant’s calls were placed to telephone number assigned to a  cellular telephone service for which Plaintiff incurs a charge for incoming calls  pursuant to 47 U.S.C. § 227(b)(1).    18.  Plaintiff brings this action individually and on behalf of all others  similarly situated, as a member of the proposed class (hereinafter, “The Class”),  defined as follows:  All persons within the United States who received any  solicitation/telemarketing  telephone  calls  from  Defendant to said person’s cellular telephone made  through the use of any automatic telephone dialing  system or an artificial or prerecorded voice and such  person had not previously consented to receiving such  calls within the four years prior to the filing of this  Complaint   8.  Beginning in or around July of 2018, Defendant contacted Plaintiff on  Plaintiff’s home telephone number ending in -6241, in an attempt to solicit Plaintiff  to purchase Defendant’s services.     9.  Defendant used an “automatic telephone dialing system” as defined  by 47 U.S.C. § 227(a)(1) to place its call to Plaintiff seeking to solicit its services.    Knowing and/or Willful Violations of the Telephone Consumer Protection  Act   47 U.S.C. §227(b)   As a result of Defendant’s willful and/or knowing violations of 47  U.S.C. §227(b)(1), Plaintiff and The Class members are entitled to  and request treble damages, as provided by statute, up to $1,500, for  each and every violation, pursuant to 47 U.S.C. §227(b)(3)(B) and 47  U.S.C. §227(b)(3)(C).    Any and all other relief that the Court deems just and proper.   Negligent Violations of the Telephone Consumer Protection Act  47 U.S.C. §227(b)   As a result of Defendant’s negligent violations of 47 U.S.C.  §227(b)(1), Plaintiff and The Class members are entitled to and  request $500 in statutory damages, for each and every violation,  pursuant to 47 U.S.C.  227(b)(3)(B).    Any and all other relief that the Court deems just and proper. 