11. At all times relevant, Plaintiff was a citizen of the State of California.   Plaintiff is, and at all times mentioned herein was, a “person” as defined by  47 U.S.C. § 153 (10).   12. Defendant is, and at all times mentioned herein was, an Iowa corporation  and a “person,” as defined by 47 U.S.C. § 153 (10).   13. At all times relevant Defendant conducted business in the State of California  and in the County of San Diego, and within this judicial district.   14. CBE is a nationwide leader in the consumer debt recovery industry.   15. Beginning in or around June of 2012, Defendant contacted Plaintiff on her  cellular telephone ending in “5599,” in an attempt to collect an alleged  outstanding Dish Network debt allegedly owed by a “Melissa Rodriguez.”   27. Plaintiff brings this action on behalf of herself and on behalf of and all  others similarly situated (the “Class”), consisting of: “all persons within the  United States who received any telephone call from Defendant or its agent to  said person’s cellular telephone made through the use of any automatic  telephone dialing system or with an artificial or prerecorded voice, which  call 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.”   28. Defendant and its employees or agents are excluded from the Class. Plaintiff  does not know the number of members in the Class, but the number of Class  members is known to Defendant, and Plaintiff believes the Class members  number in the several thousands, if not more. Thus, this matter should be  certified as a Class action to assist in the expeditious litigation of this matter.   29. 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 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 Defendant during those  illegal calls, and invading the privacy of said Plaintiff and the Class  members.  Plaintiff and the Class members were damaged thereby.   38. Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   42. Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   43. The foregoing acts and omissions of Defendant 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.   44. As a result of Defendant’s knowing and/or willful violations of 47 U.S.C. §  227 et seq., Plaintiff and The Class are entitled to an award of $1,500.00 in  statutory damages, for each and every violation, pursuant to 47 U.S.C. §  227(b)(3)(B) and 47 U.S.C. § 227(b)(3)(C).   45. 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.   THE TCPA, 47 U.S.C. § 227 ET SEQ.  • As a result of Defendant’s knowing and/or willful violations of 47 U.S.C.  § 227(b)(1), Plaintiff seeks for herself and each Class member $1,500.00  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. 