22. Plaintiff seek to represent two classes of individuals ("the Classes") defined as follows: ClassA: Allpersons intheUnited States, from four years priorto thefiling oftheinstant Complaint through the date ofthe filing ofthe instant Complaint, towhom, without obtaining the persons' prior express consent, Defendant, using an automatic telephone dialing system as defined in theTCPA, and/oran artificial or prerecorded voicemade, initiated and/orcaused to be initiated any calls to the persons' cellular telephones or residential telephones, that dehvered a message identical or substantially similar to the message described above that was left for Plaintiff Class B: All persons in the United States, from October 16, 2013, through the date of the filing of the instant Complaint, to whom, without obtaining the persons' prior express written consent, Defendant, using an automatic telephone dialing system as defined in the TCPA, and/or an artificial or prerecorded voice, made, initiated and/or caused to be initiated any calls to the persons' cellular telephones or residential telephones that delivered a message identical or substantially similar to the message described above that was left for Plaintiff  23. Numerositv: The Classes are so numerous that joinder of all individual members in one action would be impracticable. The disposition of the individual claims of the respective Classes' members through this class action will benefit both the parties and this Court.  24. Upon information and belief Classes A and B contain at a minimum thousands of members.  26. Members of the Classes may be notified of the pendency of this action by techniques and forms commonly used in class actions, such as by published notice, e-mail notice, website notice, fax notice, first class mail, orcombinations thereof, orbyother methods suitable totheClasses and deemed necessary and/or appropriate bythe Court.  27. Typicality: Plaintiff's claims are typical of the claims of the members of the Classes. The claims of the Plaintiff and members of the Classes are based on the same legal theories and arise fi:om the same unlawful conduct.  28. Defendant, using anautomatic telephone dialing system within themeaning of the TCPA, and/or an artificial or prerecorded voice, made, initiated and/or caused to be initiated at least one telephone call to Plaintiff and each member of class A, without obtaining the called parties' prior express consent, that delivered a message identical or substantially similar to the message described above that was left for Plaintiff.  29. Defendant, using an automatic telephone dialing system as defined in the TCPA, and/or an artificial or prerecorded voice, made, initiated and/or caused to be initiated at least one telephone callto Plaintiffand eachmemberof Class B, withoutobtaining the calledparties' prior express written consent, that delivered a message identical or substantially similar to the message described above that was left for Plaintiff.  30. Common Questions of Fact and Law: There is a well-defined community of common questions offact and law affecting the Plaintiffand members ofthe Classes.  33. Adequacy of Representation: Plaintiff is an adequate representative of the Classes because Plaintiffs interests do not conflict with the interests of the members of the Classes. Plaintiff will fairly, adequately and vigorously represent and protect the interests of the members ofthe Classes and has no interests antagonistic to the members ofthe Classes. Plaintiff has retained counsel who is competent and experienced in litigation in the federal courts and class action litigation.  35. Iniunctive Relief: Defendant has acted on grounds generally applicable to Plaintiff and members of Classes A and B, thereby making appropriate final injunctive relief with respect to Plaintiffand the members ofClasses A and B as a whole. 36. Plaintiff repeats each and every allegation contained in all of the above paragraphs and incorporates such allegations by reference.  37. By Defendant's above-described conduct, Defendant committed thousands of violations ofthe TCPA against Plaintiffand the members ofClass A.  38. Accordingly, Plaintiff and the members of Class A are entitled to statutory damages from Defendant under 47 U.S.C. § 227(b)(3) of greater than $5,000,000 and an injunction against Defendant ordering it to cease their violations ofthe TCPA.  39. If it is found that Defendant willfully and/or knowingly violated the TCPA, Plaintiff and the members of Class A request an increase by the Court of the damage award against Defendant, described in the preceding paragraph, to three times the amount available under 47 U.S.C. § 227(b)(3)(B), as authorized by 47 U.S.C. § 227(b)(3) for willfiil or knowing violations, which amounts to greater than $15,000,000. 41. By Defendant's above-described conduct, Defendant committed thousands of violations ofthe TCPA against Plaintiffand the members ofClass B.  42. Accordingly, Plaintiff and the members of Class B are entitled to statutory damages from Defendant under 47 U.S.C. § 227(b)(3) of greater than $5,000,000 and an injunction against Defendant ordering Defendant to cease its violations ofthe TCPA.  43. If it is found that Defendant willfully and/or knowingly violated the TCPA, Plaintiff and the members of Class B request an increase by the Court of the damage award against Defendant, described in the preceding paragraph, to three times the amount available under 47 U.S.C. § 227(b)(3)(B), as authorized by 47 U.S.C. § 227(b)(3) for willful or knowing violations, which amounts to greater than $3,750,000.