26.  Defendant is one of the world’s largest passenger-cruise lines, offering cruises,  vacation packages, and other travel services to consumers nationwide. In efforts to drum-up business,  Defendant would uniformly send marketing text messages to hundreds, if not thousands, of consumers  at a time and provided different types of offers and savings for future purchases.     27.  Upon information and belief, Defendant has sent at least one thousand illegal text  messages over the last four years preceding this lawsuit.   38.  Plaintiff brings this action on behalf of two (2) nationwide classes of similarly situated  individuals.   39.  The first class is the “No Consent to Text Class,” of which is defined as:   [1] All persons in the United States [2] within the four years  immediately preceding the filing of this Complaint [3] whose cellular  telephone number [4] was sent one or more text message [5] marketing,  advertising, and/or otherwise promoting goods, services, or events [6]  from Defendant, or another person or entity acting on Defendant’s  behalf, [7] by and through an automatic telephone dialing system or  equipment [8] and Defendant lacked the class member’s express written  consent to send such text message(s).   40.  Plaintiff is a member of the No Consent to Text Class.   41.  The second class is the “DNC Class,” of which is defined as:   [1] All persons in the United States [2] within the four years  immediately preceding the filing of this Complaint [3] whose cellular  telephone number [4] was sent one or more text message [5] marketing,  advertising, and/or otherwise promoting goods, services, or events [6]  from Defendant, or another person or entity acting on Defendant’s  behalf, [7] whereby said cellular telephone number was placed on the  national do-not-call registry more than thirty-one (31) days prior to the  class member being sent the subject text message(s) [8] and Defendant  lacked the class member’s express written consent to send such text  message(s).   42.  Plaintiff is a member of the DNC Class.   43.  Defendant and their employees or agents, Plaintiff’s attorneys and employees, the  Judge this action is assigned and any member of the Judge’s staff and immediate family, and claims  for personal injury, wrongful death, and/or emotional distress are excluded from the Classes.   44.  The Classes are so numerous and geographically widespread that joinder is  impracticable. Upon information and belief, as well as common experience of the size of automated  dialing campaigns, there are easily more than one thousand persons in each Class.    53.  Plaintiff re-alleges and incorporates paragraphs 1-52 as if fully set forth herein.   54.  It is a violation of the TCPA, 47 U.S.C. §227(b) to call a person's cellular telephone  using an automatic telephone dialing system. The TCPA also specifically prohibits the use of an  unsolicited text messages to advertise the sale of goods and services. 47 U.S.C. § 227(b)(1)(B); 47  58.  Plaintiff re-alleges and incorporates paragraphs 1-52 as if fully set forth herein.    59.  It is a violation of the TCPA, 47 U.S.C. §227(c) to call a person who has registered his  or her telephone number on the national do-not-call registry of persons who do not wish to receive  telephone solicitations. 47 U.S.C. § 227(c); 47 C.F.R. § 64.1200.   60.  Defendant, or some person on its behalf, sent one or more marketing text messages to  Plaintiff and others’ cellular telephone numbers when said numbers had been registered on the  national do-not-call registry for more than 31 days.   61.  Such text messages were sent without Plaintiff’s or the class members’ express written  consent.   62.  Defendant's text messages were negligently placed, or alternatively, willfully placed  despite prior knowledge of the TCPA.   63.  WHEREFORE, Plaintiff requests that the Court enter judgment in favor of herself  and the class and against Defendant that provides the following relief:  (A)  Statutory damages of $500 per violation, and up to $1,500 per violation if  proven to be willful;  (B)  A permanent injunction prohibiting Defendant from violating the TCPA in the  future through calling cell phones registered with the national do-not-call  registry;  (C)  A declaration that Defendant made calls to numbers registered with the  national do-not-call registry, and violated the TCPA in making such calls to  the cell phones of Plaintiff and the class; and  (D)  Any other relief the Court finds just and proper.  VIOLATION OF 47 U.S.C. § 227(b)   (THE NO CONSENT TO TEXT CLASS)   VIOLATION OF 47 U.S.C. § 227(c)   (THE DNC CLASS)  