11.  At all relevant times, Plaintiff was an individual residing in the State of Florida.  He  is a “person” as defined by 47 U.S.C. § 153(39), and the “called party.” See Breslow v. Wells  Fargo Bank, N.A., 755 F. 3d 1265 (11th Cir. 2014) and Osorio v. State Farm Bank, F.S.B., 746  F.3d 1242 (11th Cir. 2014).   12.  Plaintiff is the owner and customary user of cellular telephone number (xxx) xxx- 5808 (redacted for privacy).  Plaintiff was the called party and recipient of Defendant’s calls, as  described herein.   13.  Plaintiff registered his cellular phone with the National Do Not Call Registry on  January 23, 2007.   14.  Between approximately October of 2018 to the present, Defendant placed, or  caused to be placed, approximately 100 automated calls to Plaintiff’s cellular telephone number  using an automatic telephone dialing system (“ATDS”) or pre-recorded or artificial voice.   15.  When receiving many of these calls, Plaintiff was in his home, attempting to enjoy  the seclusion of his private domain, uninterrupted by unwanted calls and annoyances of the outside  world.  The calls intruded upon Plaintiff’s seclusion within his home and interrupted his peaceful  enjoyment thereof.    17.  When Plaintiff spoke with a representative, she identified herself as calling from  National Debt Relief and was soliciting for the company’s services.  Plaintiff asked for the calls to  stop but the calls continued.   18.  These unwanted and illegal robocalls were very upsetting and frustrating to the  Plaintiff and left him with a feeling of helplessness to stop these calls.   19.  Plaintiff is not now, nor has he ever been, a National Debt Relief customer.  He  does not have an account or business relationship with National Debt Relief.    20.  Plaintiff did not provide his cellular telephone number to Defendant, nor did he  ever provide express consent to Defendant to place calls to his cellular telephone for any reason.    21.  Plaintiff requested to opt out of, or for cessation of, Defendant’s calls however, he  continued to receive calls.   22.  All of the calls that Defendant placed and sent, or caused to be placed and sent, to  Plaintiff’s cellular telephone number were placed and sent using an ATDS or pre-recorded or  artificial voice, which has the capacity to store or produce telephone numbers to be called, using a  random or sequential number generator (including but not limited to a predictive dialer) or an  artificial or pre-recorded voice and to dial such numbers, as specified by 47 U.S.C § 227(a)(1).    23.  The telephone number Defendant used to contact Plaintiff via an ATDS or pre- recorded or artificial voice was assigned to a cellular telephone service, as described in 47 U.S.C.  § 227(b)(1)(A)(iii).   25.  Defendant’s placement of calls using an ATDS or pre-recorded or artificial voice  for non-emergency purposes and without Plaintiff’s prior express consent violated 47 U.S.C.  § 227(b)(1)(A).   26.  Consumers who do not want to receive telemarketing calls may indicate their  preference by registering their telephone numbers on the national Do Not Call Registry. 47 C.F.R.  § 64.1200(c)(2). According to the Federal Trade Commission, the Registry, which was established  in 2003, currently has over 239,000,000 active registrations.   27.  These registrations must be honored indefinitely, or until the registration is  cancelled by the consumer or the telephone number is removed by the database administrator. Id.   28.  Because a telephone subscriber listed on the Registry must take an affirmative step  to register his or her number, a telemarketer who wishes to call a person listed on the Registry  must take a similarly affirmative step, and must obtain the registrant’s signed, written agreement  to be contacted by the telemarketer. Id. § 64.1200(c)(2)(ii). The written agreement must also  include the telephone number to which the calls may be placed. Id.   29.  A person whose number is on the Registry and has received more than one  telephone solicitation within any twelve-month period by or on behalf of the same entity in  violation of the TCPA, can sue the violator and seek the greater of actual damages or $500, a  figure that may be trebled for willful or knowing violations. 47 U.S.C. § 227(c)(5).   31.  To avoid violating the TCPA by calling registered numbers, telemarketers must  scrub their call lists against the Registry at least once every thirty-one days. See 16 C.F.R.  § 310.4(b)(3)(iv).   32.  It has long been the law that a seller of goods or services can be liable for TCPA  violations even if the seller does not directly place or initiate the calls.   33.  The provision that establishes a private right of action against an entity that violates  the DNC Registry restrictions provides that “[a] person who has received more than one telephone  call within any 12-month period by or on behalf of the same entity in violation of the regulations  prescribed under this subsection” may bring an action for damages and injunctive relief.  47  U.S.C. § 227(c)(5) (emphasis added).   34.  Defendant has a corporate policy to use an ATDS or a pre-recorded or artificial  voice to place calls to individuals, just as it did to Plaintiff’s cellular telephone here.   35.  Defendant has a corporate policy to use an ATDS or a pre-recorded or artificial  voice, just as it did to the Plaintiff’s cellular telephone in this case, with no way for the consumer  to cease the placement of calls.   36.  Defendant’s corporate policy is structured so as to continue to place calls to  individuals like Plaintiff, despite the fact these consumers request that Defendant cease the  placement of calls.   38.  Defendant has a corporate policy to harass and abuse individuals despite actual  knowledge that the called parties do not wish to be called.   39.  As a result of each of the calls described above, Plaintiff and putative Class  Members suffered an invasion of privacy, as well as particularized and concrete injuries, including  the inducement of stress, anxiety, nervousness, embarrassment, distress, and/or aggravation.  Plaintiff and putative Class Members also suffered out-of-pocket losses, including the monies paid  to their wireless carriers for the receipt of such calls.  Additionally, due to both the answered and  unanswered calls placed by Defendant, Plaintiff and putative Class Members suffered the  expenditure of their time, exhaustion of their cellular telephone batteries, unavailability of their  cellular telephones while Defendant’s calls were incoming, and trespass upon their respective  chattels. All of the above-mentioned injuries were caused by, and/or directly related to,  Defendant’s placement of calls to Plaintiff and putative Class Members by using an ATDS to call  their cellular telephone numbers.   40.  In response to Defendant’s unlawful conduct, Plaintiff filed this lawsuit and seeks  an injunction requiring Defendant to cease all unsolicited cellular telephone calls and an award of  statutory damages and actual damages to putative Class Members under the TCPA, together with  costs and reasonable attorneys’ fees.  42.  Excluded from the Class are Defendant, its employees, agents and assigns, and any  members of the judiciary to whom this case is assigned, their Court staff, and Plaintiff’s counsel.  Members of the above-defined Class can be easily identified through Defendant’s records or those  of its vendors who placed the calls and/or sent the text messages at issue on behalf of Defendant.  Numerosity   44.  The alleged size and geographic disbursement of the putative Class, and relatively  modest value of each individual claim, makes joinder of all Class Members impracticable or  impossible.    Predominance of Common Questions of Law and Fact   46.  Plaintiff’s claims are typical of the claims of the putative Class Members, as  Plaintiff and Class Members have been injured by Defendant’s uniform misconduct – the  placement of calls to cellular telephones using an ATDS or artificial or pre-recorded voice for non- emergency purposes and without prior express consent.   47.  Plaintiff shares the aforementioned facts and legal claims and/or questions with all  putative Class Members. Further, a sufficient relationship exists between Defendant’s conduct and  the damages sustained by Plaintiff and putative Class Members.  Adequacy   51.  Without prior express consent, Defendant placed calls for non-emergency purposes  to the cellular telephones of Plaintiff and Class Members using an ATDS or artificial or pre- recorded voice with the capacity to store or produce telephone numbers to be called.   52.  The foregoing acts constitute numerous and multiple negligent violations of the  TCPA, including, but not limited to, each of the above-cited provisions of 47 U.S.C. §§ 227, et  seq.   53.  Under 47 U.S.C. § 227(b)(3)(B), and as a result of the alleged negligent violations  of the TCPA, Plaintiff and Class Members are entitled to an award of $500.00 in statutory  damages for each and every non-emergency call placed and text message sent in violation of the  56.  Plaintiff incorporates by reference the allegations in Paragraphs 1 through 49, as  though fully set forth herein.   58.  The foregoing acts constitute numerous and multiple knowing and/or willful  violations of the TCPA, including, but not limited to, each of the above cited provisions of 47  U.S.C. §§ 227, et seq.   59.  Pursuant to 47 U.S.C. § 227(b)(3)(B), and as a result of the alleged knowing and/or  willful violations of the TCPA, Plaintiff and Class Members are entitled to an award of $1,500.00  in statutory damages for each and every non-emergency call placed in violation of the statute.   60.       Plaintiff and Class Members are also entitled to and seek injunctive relief prohibiting  future violations of the TCPA.   61.  Plaintiff and Class Members are also entitled to an award of costs and expenses.  Knowing and/or Willful Violation of the Telephone Consumer Protection Act  47 U.S.C. §§ 227, et seq.   Negligent Violation of the Telephone Consumer Protection Act  47 U.S.C. §§ 227, et seq.  