10.  Defendant contacted or attempted to contact Plaintiff from telephone  20  numbers belonging to Defendant, including without limitation (561) 220-9418.  21   11  Negligent Violations of the Telephone Consumer Protection Act  12  47 U.S.C. §227(c)  13  •As a result of Defendant's negligent violations of 47 US. C.  14  §227(c)(5), Plaintiff and the DNC Class and DNC Revocation Class  15  members are entitled to and request $500 in statutory damages, for  16  each and every violation, pursuant to 47 US. C.. 227(c)(5).  17  •Any and all other relief that the Court deems just and proper.  18  11.  Defendant's calls constituted calls that were not for emergency  22  purposes as defined by 47 US.C. § 227(b)(J)(A).  23   12.  Defendant's calls were placed to a telephone number assigned to a  24  cellular telephone service for which Plaintiff incurs a charge for incoming calls  25  pursuant to 47 US.C. § 227(b)(J).  26   13   13.  During all relevant times, Defendant did not possess Plaintiffs "prior  27  express consent" to receive calls using an automatic telephone dialing system or an  28  artificial or prerecorded voice on its cellular telephones pursuant to 47 US. C. §  19  Knowing and/or Willful Violations of the Telephone Consumer Protection  20  Act  21  47 U.S.C. §227(c)  22  •As a result of Defendant's willful and/or knowing violations of 47  23  US.C. §227(c)(5), Plaintiff and the DNC Class and DNC Revocation  24  Class members are entitled to and request treble damages, as provided  25  by statute, up to $1,500, for each and every violation, pursuant to 47  26  US.C. §227(c)(5).  27  •Any and all other relief that the Court deems just and proper.  28  20  Negligent Violations of the Telephone Consumer Protection Act  21  47 u.s.c. §227(b)  22  •As a result of Defendant's negligent violations of 47 US. C.  23  §227(b)(J), Plaintiff and the ATDS Class and ATDS Revocation  24  Class members are entitled to and request $500 in statutory damages,  25  for each and every violation, pursuant to 47 US.C. 227(b)(3)(B).  26  •Any and all other relief that the Court deems just and proper.  27  21.  Plaintiff brings this action individually and on behalf of all others  26  similarly situated, as a member the four proposed classes (hereafter, jointly, "The  27  Classes"). The class concerning the A TDS claim for no prior express consent  28  (hereafter "The ATDS Class") is defined as follows:  25   8.  Beginning on or about June 13, 2017 and continuing through on or  14  about July 20, 2017, Defendant contacted Plaintiff on Plaintiffs cellular telephone  15  number ending in -7558 in an attempt to solicit Plaintiff to purchase Defendant's  16  services or products.  17   9.  Defendant used an "automatic telephone dialing system" as defined  18  by 47 US.C. § 227(a)(J) to place its calls to Plaintiff seeking to solicit its services.  19  