10.  Beginning in or around February 2016, Defendants contacted Plaintiff  on Plaintiff’s cellular telephone number ending in -1554, in an attempt to solicit  Plaintiff to purchase Defendants’ services.     11.  Defendants used an “automatic telephone dialing system” as defined  by 47 U.S.C. § 227(a)(1) to place its call to Plaintiff seeking to solicit its services.    12.  Defendants contacted or attempted to contact Plaintiff from telephone  number (415) 550-6970 at least once on or around February 3, 2016 and at least  once on March 9, 2016.    13.  Defendants’ calls constituted calls that were not for emergency  purposes as defined by 47 U.S.C. § 227(b)(1)(A).   14.  Defendants’ calls were placed to telephone number assigned to a  cellular telephone service for which Plaintiff incurs a charge for incoming calls  pursuant to 47 U.S.C. § 227(b)(1).    15.  During all relevant times, Defendants did not possess Plaintiff’s “prior  express consent” to receive calls using an automatic telephone dialing system or an  artificial or prerecorded voice on his cellular telephone pursuant to 47 U.S.C. §  227(b)(1)(A).   16.  Further, Plaintiff’s cellular telephone number ending in -1554 was  added to the National Do-Not-Call Registry on or about December 16, 2004.   17.  Despite this, Defendants continued to call Plaintiff in an attempt to  solicit its services and in violation of the National Do-Not-Call provisions of the  22.  Plaintiff brings this action individually and on behalf of all others  similarly situated, as a member the two proposed classes (hereafter, jointly, “The  Classes”). The class concerning the ATDS claim for no prior express consent  (hereafter “The ATDS Class”) is defined as follows:  All persons within the United States who received any  solicitation/telemarketing  telephone  calls  from  Defendant to said person’s cellular telephone made  through the use of any automatic telephone dialing  system or an artificial or prerecorded voice and such  person had not previously consented to receiving such  calls within the four years prior to the filing of this  Complaint   54.  Pursuant to the Seventh Amendment to the Constitution of the United  States of America, Plaintiff is entitled to, and demands, a trial by jury.  Respectfully Submitted this 21st Day of October, 2016.  Knowing and/or Willful Violations of the Telephone Consumer Protection  Act   47 U.S.C. §227(b)   As a result of Defendant’s willful and/or knowing violations of 47  U.S.C. §227(b)(1), Plaintiff and the ATDS Class members are  entitled to and request treble damages, as provided by statute, up to  $1,500, for each and every violation, pursuant to 47 U.S.C.  §227(b)(3)(B) and 47 U.S.C. §227(b)(3)(C).    Any and all other relief that the Court deems just and proper.   Knowing and/or Willful Violations of the Telephone Consumer Protection  Act   47 U.S.C. §227(c)   As a result of Defendant’s willful and/or knowing violations of 47  U.S.C. §227(c)(5), Plaintiff and the DNC Class members are entitled  to and request treble damages, as provided by statute, up to $1,500,  for each and every violation, pursuant to 47 U.S.C. §227(c)(5).    Any and all other relief that the Court deems just and proper.    Negligent Violations of the Telephone Consumer Protection Act  47 U.S.C. §227(b)   As a result of Defendant’s negligent violations of 47 U.S.C.  §227(b)(1), Plaintiff and the ATDS Class members are entitled to and  request $500 in statutory damages, for each and every violation,  pursuant to 47 U.S.C.  227(b)(3)(B).    Any and all other relief that the Court deems just and proper. 