14.  Beginning on or about September 15, 2017, Plaintiff began receiving  text messages from Defendant on his cellular telephone number ending in -7558.    26.  Plaintiff brings this action on behalf of himself and on behalf of and  all others similarly situated (“the Class”).   27.  Plaintiff represents, and is a member of, the Class, consisting of the  following:  all persons within the United States who received any  unsolicited text messages from Defendant which text  message was not made for emergency purposes or with the  recipient’s prior express consent within the four years  prior to the filing of this Complaint.   38.  Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   39.  The foregoing acts and omissions of Defendant constitutes 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.   40.  As a result of Defendant’s 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)(B).   41.  Plaintiff and the Class are also entitled to and seek injunctive relief  prohibiting such conduct in the future.  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.  ON BEHALF OF PLAINTIFF AND THE CLASS AGAINST DEFENDANT   THE TCPA, 47 U.S.C. § 227 ET SEQ.   As a result of Defendant’s 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)(B).   Pursuant to 47 U.S.C. § 227(b)(3)(A), injunctive relief prohibiting such  conduct in the future.   Any other relief the Court may deem just and proper. 