26.  Plaintiff Hidenrick registered her cellular number on the National Do Not Call  Registry on July 27, 2003 in order to avoid receiving unsolicited telemarketing calls.   35.  Plaintiff brings this action pursuant to Federal Rule of Civil Procedure 23(b)(2)  and Rule 23(b)(3) on behalf of herself and all others similarly situated and seeks certification of  the following Classes:  Autodialed No Consent Class: All persons in the United States who,  from four years prior to the filing of this action through the present, (1)  Defendants (or a third person acting on behalf of Defendants) called, (2)  on the person’s cellular telephone, (3) using an autodialer, (4) for the  purpose of selling Defendants’ products and/or services, and (5) for whom  Defendants claims they obtained prior express written consent in the same  manner as Defendants claims they supposedly obtained prior express  written consent to call the Plaintiff or do not claim to have consent.  Autodialed Stop Class: All persons in the United States who from, four  years prior to the filing of this action to the present, (1) Defendants (or a  third person acting on behalf of Defendants) called, (2) on the person’s  cellular telephone, (3) using an automated telephone dialing system, (4)  after the person informed Defendants that s/he no longer wished to receive  phone calls from Defendants.  Do Not Call Registry Class: All persons in the United States who, from  four years prior to the filing of this action through the present, (1) received  more than one call made by or on behalf of Defendants within a 12-month  period, (2) for the purpose of selling Defendants’ products and/or services,  (3) after his/her telephone number(s) was registered with the National Do  Not Call registry for at least thirty days, and (4) for whom Defendants  claims they obtained prior express written consent in the same manner as  Defendants claims they supposedly obtained prior express written consent  to call the Plaintiff or do not claim to have consent.   41.  Plaintiff incorporates paragraphs 1 through 40 as if fully set forth herein.   42.  Defendants made autodialed solicitation telephone calls to cellular telephone  numbers belonging to Plaintiff and other members of the Autodialed No Consent Class without  first obtaining prior express written consent to make such calls.   46.  Plaintiff incorporates paragraphs 1 through 40 as if fully set forth herein.    47.  Defendants placed unsolicited and unwanted calls to telephone numbers  belonging to Plaintiff and the other members of the Autodialed Stop Class on their cellular  telephones after they had informed Defendants by phone to stop contacting them.    48.  Defendants placed the calls using equipment that had the capacity to store or  produce telephone numbers to be called and/or texted using a random or sequential number  generator, and/or receive and store lists of phone numbers, and to dial such numbers, en masse.   49.  By placing unsolicited phone calls to Plaintiff and other members of the  Autodialed Stop Class’s cellular telephones using an automated telephone dialing system after  they requested to no longer receive such calls, Defendants violated 47 U.S.C. § 227(b)(1)(B) by  doing so without prior express written consent.   52.  Plaintiff incorporates paragraphs 1 through 40 as if fully set forth herein.    53.  Defendants violated 47 C.F.R. §64.1200 by initiating calls for telemarketing  purposes to cellular telephone subscribers such as Plaintiff and the Do Not Call Registry Class  who were registered on the National Do Not Call Registry, and who received two or more  additional calls within a 12-month period from Defendants without their consent. Defendants  made these calls without instituting procedures that comply with the regulatory minimum  standards for maintaining a list of persons who should not be called.   54.  As a result of Defendants’ unlawful conduct, Plaintiff and the Do Not Call  Registry Class suffered actual damages and, under section 47 U.S.C. § 227(c), Plaintiff and each  member of the Do Not Call Registry Stop Class are each entitled to receive up to $500 in  damages for each violation of 47 C.F.R. § 64.1200.   55.  Should the Court determine that Defendants conduct was willful and knowing, the  Court may, pursuant to Section 227(b)(3), treble the amount of statutory damages recoverable by  Plaintiff and the other members of the Do Not Call Registry Stop Class.  7.  Defendants contact consumers without their prior express written consent in an  effort to solicit them to purchase alarm monitoring services.     Telephone Consumer Protection Act  (Violation of 47 U.S.C. § 227)  (On Behalf of Plaintiff and the Do Not Call Registry Stop Class)   Telephone Consumer Protection Act   (Violation of 47 U.S.C. § 227)  (On Behalf of Plaintiff and the Autodialed Stop Class)   Telephone Consumer Protection Act  (Violations of 47 U.S.C. § 227 et seq.)  (On Behalf of Plaintiff and the Autodialed No Consent Class)  