14. At all times relevant, Plaintiff was a citizen of the State of California.  Plaintiff is, and at all times mentioned herein was, “persons” as defined by  43. Plaintiff brings this action on behalf of himself and on behalf of all others  similarly situated (“the Class”).   45. GLOBAL and their employees or agents are excluded from the Class.  Plaintiff does not know the number of members in the Class, but believes  the Class members number in the thousands, if not more.  Thus, this matter  should be certified as a Class action to assist in the expeditious litigation of  this matter.   46. Plaintiff and members of the Class were harmed by the acts of Defendants in  at least the following ways: Defendants illegally contacted Plaintiff and the  Class members via their cellular telephones thereby causing Plaintiff and the  Class members to incur certain cellular telephone charges or reduce cellular  telephone time for which Plaintiff and the Class members previously paid,  by having to retrieve or administer  messages left  by Defendants or their  agents, during those illegal calls, and invading the privacy of said Plaintiff  and the Class members.  Plaintiff and the Class members were damaged  thereby.   47. This suit seeks only damages and injunctive relief for recovery of economic  injury on behalf of the Class and it expressly is not intended to request any  recovery for personal injury and claims related thereto.  Plaintiff reserves the  right to expand the Class definition to seek recovery on behalf of additional  persons as warranted as facts are learned in further investigation and  discovery.   48. The joinder of the Class members is impractical and the disposition of their  claims in the Class action will provide substantial benefits both to the parties  and to the Court.  The Class can be identified through Defendants’ records  and/or Defendants’ agent’s records.   50. As a person who received calls from Defendants in which Defendants used  an ATDS or an artificial or prerecorded voice, without Plaintiff’s prior  express consent, Plaintiff is asserting claims that are typical of the Class.  Plaintiff will fairly and adequately represent and protect the interests of the  Class in that Plaintiff has no interests antagonistic to any member of the  Class.   51. Plaintiff and the members of the Class have all suffered irreparable harm as  a result of the Defendants’ unlawful and wrongful conduct.  Absent a class  action, the Class will continue to face the potential for irreparable harm.  In  addition, these violations of law will be allowed to proceed without remedy  and Defendants will likely continue such illegal conduct.  The size of Class  member’s individual claims causes, few, if any, Class members to be able to  afford to seek legal redress for the wrongs complained of herein.   53. A class action is a superior method for the fair and efficient adjudication of  this controversy.  Class-wide damages are essential to induce Defendants to  comply with federal and California law.  The interest of Class members in  individually controlling the prosecution of separate claims against  Defendants is small because the maximum statutory damages in an  individual action for violation of privacy are minimal.  Management of these  claims is likely to present significantly fewer difficulties than those that  would be presented in numerous individual claims.   54. Defendants have acted on grounds generally applicable to the Class, thereby  making appropriate final injunctive relief and corresponding declaratory  relief with respect to the Class as a whole.  55. Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   56. The foregoing acts and omissions of Defendants constitute numerous and  multiple negligent violations of the TCPA, including but not limited to each  and every one of the above-cited provisions of 47 U.S.C. § 227 et seq.   57. As a result of Defendants' negligent violations of 47 U.S.C. § 227 et seq.,  Plaintiff and the Class are entitled to an award of $500.00 in statutory  damages, for each and every violation, pursuant to 47 U.S.C. § 227(b)(3) 59. Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   60. The foregoing acts and omissions of Defendants constitute numerous and  multiple knowing and/or willful violations of the TCPA, including but not  limited to each and every one of the above-cited provisions of 47 U.S.C. §  227 et seq.   61. As a result of Defendants' knowing and/or willful violations of 47 U.S.C. §  227 et seq., Plaintiff and each of the Class are entitled to treble damages, as  provided by statute, up to $1,500.00, for each and every violation, pursuant  to 47 U.S.C. § 227(b)(3)(B) and 47 U.S.C. § 227(b)(3)(C).   62. Plaintiff and the Class are also entitled to and seek injunctive relief  prohibiting such conduct in the future.  64. As a result of Defendants' negligent violations of 47 U.S.C. § 227(b)(1),  Plaintiff  seeks  for  himself and each Class member $500.00 in statutory  damages, for each and every violation, pursuant to 47 U.S.C. § 227(b)(3) 67. As a result of Defendants' willful and/or knowing violations of 47 U.S.C. §  227(b)(1), Plaintiff seeks for himself and each Class member treble  damages, as provided by statute, up to $1,500.00 for each and every  violation, pursuant to 47 U.S.C. § 227(b)(3)(B) and 47 U.S.C. § 227(b)(3) KNOWING AND/OR WILLFUL VIOLATIONS OF THE TELEPHONE  CONSUMER PROTECTION ACT 47 U.S.C. § 227 ET SEQ.   NEGLIGENT VIOLATIONS OF THE TELEPHONE CONSUMER  PROTECTION ACT 47 U.S.C. § 227 ET SEQ.   THE TCPA, 47 U.S.C. § 227 ET SEQ.   VIOLATION  OF THE TCPA, 47 U.S.C. § 227 ET SEQ.  