12.  In 1991, Congress enacted the TCPA in response to a growing number  of consumer complaints regarding certain telemarketing practices.   39.  As a separate and distinct cause of action against all DEFENDANTS,  PLAINTIFFS reallege and incorporate by reference, as though fully set forth  herein, all the foregoing paragraphs of this Complaint as if fully stated herein,  excepting those allegations which are inconsistent with this cause of action.   40.  The foregoing acts and omissions of DEFENDANTS constitute  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.   41.  As a result of DEFENDANTS’ knowing and/or willful violations of 47  U.S.C. §§ 227, et seq., PLAINTIFFS and members of the proposed Class are  entitled to treble damages of up to $1,500.00 for each and every text message sent  in violation of the statute, pursuant to 47 U.S.C. § 227(b)(3)(C).   45.  As a separate and distinct cause of action against all DEFENDANTS,  PLAINTIFFS reallege and incorporate by reference, as though fully set forth  herein, all the foregoing paragraphs of this Complaint as if fully stated herein,  excepting those allegations which are inconsistent with this cause of action.   46.  The foregoing acts and omissions of DEFENDANTS constitute  numerous and multiple violations of the TCPA, including but not limited to each of  the above-cited provisions of 47 U.S.C. §§ 227, et seq.   47.  As a result of DEFENDANTS’ violations of 47 U.S.C. §§ 227, et seq.,  PLAINTIFFS and members of the proposed Class are entitled to an award of  $500.00 in statutory damages for each and every text message made in violation of  the statute, pursuant to 47 U.S.C. § 227(b)(3)(B).   48.  PLAINTIFFS and members of the proposed Class are also entitled to  and do seek injunctive relief prohibiting such conduct violating the TCPA by  DEFENDANTS in the future.    49.  PLAINTIFFS and members of the proposed Class are also entitled to  an award of attorneys’ fees and costs.   50.  WHEREFORE, PLAINTIFFS request relief as hereafter provided.  A.  The TCPA of 1991   KNOWING AND/OR WILLFUL VIOLATIONS  OF THE TELEPHONE CONSUMER PROTECTION ACT  (47 U.S.C. §§ 227, et seq.)   PLAINTIFFS RAMZI ABED, MICHAEL FLOWERS, LAUREN LEVITT,  and CHRISTOPHER MYRICK, individually and on behalf of themselves, all  others similarly situated, and the general public, complain and allege on  information and belief the following against DEFENDANTS MICHAEL  BLOOMBERG 2020, INC., and DOES 1-10:  VIOLATIONS OF THE TELEPHONE CONSUMER PROTECTION ACT  (47 U.S.C. §§ 227, et seq.)  