37.  Plaintiff repeats and realleges the above paragraphs of this Complaint and  incorporates them herein by reference.   38.  Defendant negligently placed multiple automated calls to cellular  numbers belonging to Plaintiff and the other members of the Class without their prior  express consent.   39.  Each of the aforementioned calls by Defendant constitutes a negligent  violation of the TCPA.   42.  Plaintiff repeats and realleges the above paragraphs of this Complaint and  incorporates them herein by reference.   43.  Defendant knowingly and/or willfully placed multiple automated calls to  cellular numbers belonging to Plaintiff and the other members of the Class without  their prior express consent.   44.  Each of the aforementioned calls by Defendant constitutes a knowing  and/or willful violation of the TCPA.   45.  As a result of Defendant’s knowing and/or willful violations of the TCPA,  Plaintiff and the Class are entitled to an award of treble damages up to $1,500.00 for  each call in violation of the TCPA pursuant to 47 U.S.C. § 227(b)(3)(B) and 47 U.S.C.  § 227(b)(3)(C).   46.  Additionally, Plaintiff and the Class are entitled to and seek injunctive  relief prohibiting such conduct by Defendant in the future.  A. The Class   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.  