10.  Abacus purchased HotDocs in November, 2017.3   11.  The text messages that Plaintiff received state that HotDocs requires an update:   26.  Plaintiff brings this action pursuant to Federal Rule of Civil Procedure 23(b)(2)  and Rule 23(b)(3) on behalf of himself and all others similarly situated and seeks certification of  the following Classes:  Autodialed No Consent Class: All persons in the United States who from four  years prior to the filing of this action through class certification (1) Defendant (or  an agent acting on behalf of Defendant) text messaged, (2) on the person’s cellular  telephone number, (3) using a text messaging platform substantially similar to the  text messaging platform Defendant used to text message Plaintiff, (4) for whom  Defendant claims (a) it obtained prior express written consent in the same manner  as Defendant claims it supposedly obtained prior express written consent to text  message Plaintiff, or (b) it did not obtain prior express written consent.  Do Not Call Registry Class: All persons in the United States who from four years  prior to the filing of this action through class certification (1) Defendant (or an agent  acting on behalf of Defendant) texted more than one time; (2) within any 12-month  period (3) where the person’s telephone number had been listed on the DNC for at  least thirty days; (4) for a substantially similar reason that Defendant texted  Plaintiff; and (5) for whom Defendant claims (a) it obtained prior express written  consent in the same manner as Defendant claims it supposedly obtained prior  express written consent to text message Plaintiff, or (b) Defendant did not obtain  prior express written consent.   32.  Plaintiff repeats and realleges paragraphs 1 through 31 of this Complaint and  incorporates them by reference.   33.  Defendant and/or its agents sent unwanted solicitation text messages to cellular  telephone numbers belonging to Plaintiff and the other members of the Autodialed No Consent  Class using an autodialer.    34.  These solicitation text messages were sent en masse without the consent of the  Plaintiff and the other members of the Autodialed No Consent Class to receive such solicitation  text messages.   35.  Defendant has, therefore, violated 47 U.S.C. § 227(b)(1)(A)(iii). As a result of  Defendant’s conduct, Plaintiff and the other members of the Autodialed No Consent Class are  each entitled to, under 47 U.S.C. § 227(b)(3)(B), a minimum of $500.00 in damages for each  violation of such act.   36.  In the event that the Court determines that Defendant’s conduct was willful and  knowing, it may, under 47 U.S.C. § 227(b)(3)(C), treble the amount of statutory damages  recoverable by Plaintiff and the other members of the Autodialed No Consent Class.  Abacus Violates the TCPA By Sending Autodialed Text Messages to Consumers,  Including to Consumers Who Have Registered their Phone Numbers on the DNC   Class Treatment Is Appropriate for Plaintiff’s TCPA Claims    Telephone Consumer Protection Act  (Violations of 47 U.S.C. § 227)  (On Behalf of Plaintiff and the Autodial No Consent Class)  