1. Plaintiff alleges that at all times relevant herein Defendant conducted  business in the State of Ohio, County of Lake, and within this judicial  district.   12. Plaintiffs bring this action on behalf of themselves and on behalf of all  others similarly situated (“the Class”).   13. Plaintiffs represent, and are members of the Class, consisting of all persons  within the United States who received any telephone call from Defendant or  their agent/s and/or employee/s to said person’s residential 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 within the four years prior to the filing of this Complaint.   14. Defendant and its employees or agents are excluded from the Class.   Plaintiffs do not know the number of members in the Class, but believe the  Class members number in the hundreds of thousands, if not more.  Thus, this  matter should be certified as a Class action to assist in the expeditious  litigation of this matter.   15. Plaintiffs and members of the Class were harmed by the acts of Defendant in  at least the following ways: Defendants, either directly or through its agents,  illegally contacted Plaintiffs and the Class members via landline telephones  by using an ATDS, thereby causing Plaintiffs and the Class members to  2. At no time did Plaintiff ever enter into a business relationship with  Defendant.   24. Plaintiffs incorporate by reference all of the above paragraphs of this  Complaint as though fully stated herein.   25. 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.   26. As a result of Defendant’s negligent violations of 47 U.S.C. § 227 et seq,  Plaintiffs 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).   27. Plaintiffs and the Class are also entitled to and seek injunctive relief  prohibiting such conduct in the future.  28. Plaintiffs incorporate by reference all of the above paragraphs of this  Complaint as though fully stated herein.   29. The foregoing acts and omissions of Defendant constitutes 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.   3. Nor did Plaintiff ever contact Defendant at any time or provide Defendant  with Plaintiff’s residential telephone number.   30. As a result of Defendant’s knowing and/or willful violations of 47 U.S.C. §  227 et seq, Plaintiffs 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).  4. Beginning in May 2013, Defendant contacted Plaintiff on Plaintiff’s  residential telephone number, in an effort to solicit Plaintiff’s business.   5. Defendant placed more than one unsolicited advertisements to Plaintiff’s  residential telephone in a period of months.   6. Defendant used an “automatic telephone dialing system”, as defined by 47  U.S.C. § 227(a)(1) to place its unsolicited calls to Plaintiff while using an  “artificial or prerecorded voice” as prohibited by 47 U.S.C. § 227(b)(1)(A).   7. This ATDS has the capacity to store or produce telephone numbers to be  called, using a random or sequential number generator.   8. These telephone communications constituted telephone solicitations as  defined by 47 U.S.C. § 227(a)(4).  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), Plaintiffs seeks for themselves 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.  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),  Plaintiffs seeks for themselves 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. 