(KNOWING AND/OR WILLFUL VIOLATIONS OF THE TELEPHONE  CONSUMER PROTECTION ACT, 47 U.S.C. § 227, et seq.)   (VIOLATIONS OF THE TELEPHONE CONSUMER PROTECTION ACT, 47  U.S.C. § 227, et seq.)   15.  In 1991, Congress enacted the TCPA in response to a growing number  of consumer complaints regarding certain telemarketing practices.   32.  Plaintiffs incorporate by reference the foregoing paragraphs of this  Complaint as if fully stated herein.   33.  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 of the above-cited provisions of 47 U.S.C. § 227 et seq.   34.  As a result of Defendants’ knowing and/or willful violations of 47  U.S.C. § 227 et seq., Plaintiffs and members of the proposed class are entitled to  treble damages of up to $1,500.00 for each and every call in violation of the statute,  pursuant to 47 U.S.C. § 227(b)(3)(C).   35.  Plaintiffs and members of the proposed class are also entitled to and do  seek injunctive relief prohibiting such conduct violating the TCPA by Defendants in  the future.   37.  Plaintiffs incorporate by reference the foregoing paragraphs of this  Complaint as if fully stated herein.   38.  The foregoing acts and omissions of Defendants constitute numerous  and multiple violations of the TCPA, including but not limited to each of the above- cited provisions of 47 U.S.C. § 227 et seq.   39.  As a result of Defendants’ violations of 47 U.S.C. § 227 et seq.,  Plaintiffs and members of the proposed class are entitled to an award of $500.00 in  statutory damages for each and every call in violation of the statute, pursuant to 47  U.S.C. § 227(b)(3)(B).   40.  Plaintiffs and members of the proposed class are also entitled to and do  seek injunctive relief prohibiting such conduct violating the TCPA by Defendants in  the future.   41.  Plaintiffs and members of the proposed class are also entitled to an  award of attorneys’ fees and costs.  A.  The Telephone Consumer Protection Act Of 1991  