10.  Mr. Williams informed Plaintiff that he gave Keiser University Plaintiff's  name and telephone number in connection with an application for financial aid.   11.  Defendant used an automatic telephone dialing system or pre-recorded or  artificial voice to place calls to Plaintiff's cellular telephone without her consent.   12.  None of Defendant’s telephone calls placed to Plaintiff were for  “emergency purposes” as specified in 47 U.S.C. §227 (b)(1)(A).   13.  The messages encroached upon Plaintiff's privacy and seclusion.  14.  The class is defined as (i) all Florida citizens (ii) to whom Defendant placed  a telephone call to that person’s cellular telephone service (iii) made through the use of  any automatic telephone dialing system or an artificial or prerecorded voice, (iv) during  the four year period prior to the filing of the complaint in this matter through the date of  class certification.   15.  Plaintiff alleges on information and belief, based on Defendant’s use of  telephone messages to a cellular telephone service through an automatic telephone  dialing system or artificial voice, that the classes are so numerous that joinder of all  members is impractical.     17.  Defendant, its employees and agents are excluded from the class. Plaintiff  and members of the Class were harmed by the acts of Defendant in at least the following  ways: Defendant illegally contacted Plaintiff and the Class members via their cellular  telephones, by having to retrieve or administer messages left by Defendant during those  illegal calls, and invading the privacy of said Plaintiff and the Class members.   18.  Plaintiff's claims are typical of those of the class members.  All are based  on the same facts and legal theories.   19.  Plaintiff will fairly and adequately protect the interests of the class.  He has  retained counsel experienced in handling actions involving unlawful practices under the  TCPA  and consumer class actions.  Neither Plaintiff nor his counsel have any interests  which might cause them not to vigorously pursue this action.    20.  Certification of a class under Rule 23(b)(2) of the Federal Rules of Civil  Procedure is appropriate in that defendants have acted on grounds generally applicable to  the class thereby making appropriate declaratory relief with respect to the class as a  whole.   22.  Plaintiff requests certification of a hybrid class action combing Rule  23(b)(2) for equitable relief with Rule 23(b)(3) for monetary damages.  23.  Plaintiff incorporates Paragraphs 1 through 22.   24.  Defendant, or others acting on its behalf, placed non-emergency telephone  calls to Plaintiff’s cellular telephone using an automatic telephone dialing system or pre- recorded or artificial voice violation of 47 U.S.C § 227 (b)(1)(A)(iii).  WHEREFORE, Plaintiff requests that the Court enter judgment in favor of  Plaintiff and all similarly situated persons and against Defendant for:  a.  Statutory damages;  b.  a declaration that Defendant's calls violate the TCPA;  c.  a permanent injunction prohibiting Defendant from placing non- emergency calls to the Plaintiff and all similarly situated persons cellular  telephone using an automatic telephone dialing system or pre-recorded or  artificial voice; and  d.  Such other or further relief as the Court deems proper.  6.  Within the last four years, Defendant left repetitive pre-recorded messages  on Plaintiff’s voice mail on his cellular telephone seeking to assist a person who is a  friend of Plaintiff , Sanjay R. Williams ("Mr. Williams").   7.  Defendant, or others acting on its behalf, left the following message on  Plaintiff’s voice mail on his cellular telephone on or about the date stated:  September 26, 2016 - Pre-recorded message  Hello. This call is for Sanjay R. Williams Sanjay R. Williams we are  calling you today from the I-3 Group on behalf of Keiser University, Fort  Lauderdale. The purpose of our call today is to provide you with solutions,  assistance or information regarding your education Keiser University, Fort  Lauderdale. For your convenience you may call us toll free at 1-877-618- 3648 and or visit our website at www.I-3group.com.     8.  In addition to the foregoing, Defendant left messages on other occasions  and on still other occasions, called and hung-up without leaving any message.   VIOLATION OF THE TELEPHONE CONSUMER PROTECTION ACT  