21.  The language on the aforesaid website reads as follows:  31.   This action is brought on behalf of a class consisting of:  All persons in the United States who unsubscribed to receive text  messages from Domino’s Pizza and were subsequently sent text  message advertisements from Defendant (or any party on behalf of  Defendant) to their cellular telephone wherein said text messages  were sent using an automatic telephone dialing system or device  which has the capacity to store or produce telephone numbers to be  called using a random or sequential number generator during the four  year period prior to the filing of the complaint in this action through  the date of certification.4   33.  Plaintiff alleges on information and belief based upon the Defendant’s  use of mass text messages that the class is so numerous that joinder of all members  of the class is impractical.  There are in all likelihood several thousand individuals  in the Class as previously defined herein.   34.  There are questions of law or fact common to the class, which  common issues predominate over any issues involving only individual class  members.  The common factual and/or legal issues common to each class member  are as follows:  (a)   Whether Defendant’s conduct is governed by the TCPA?  (b)   Whether the text message advertisements sent by Defendant        after Plaintiff unsubscribed violated the TCPA?  (c)   Are the class members entitled to treble damages based upon   the willfulness of Defendant’s conduct?  (d)   Whether Defendant should be enjoined from engaging in such   conduct in the future?   36.  Plaintiff will fairly and adequately protect the interests of the class.   She has retained counsel experienced in handling actions involving unlawful  practices under the TCPA and class actions.  Neither Plaintiff nor her counsel has  any interests which might cause them not to vigorously pursue this action.   37.  Certification of the class under Rule 23(b)(3) of the Federal Rules of  Civil Procedure is also appropriate in that:  (1)  The questions of law or fact common to the members of the  class predominate over any questions affecting an individual  member.  (2)   A class action is superior to other available methods for the fair  and efficient adjudication of the controversy.   38.   Certification of a class under Rule 23(b)(2) of the Federal Rules of  Civil Procedure is also appropriate in that Defendant has acted on grounds  generally applicable to the class thereby making appropriate relief with respect to  the class as a whole.   40.   Plaintiff incorporates Paragraphs 1 through 39.   41.    Defendant sent unwanted text messages to Plaintiff and the members  of the putative class using an automatic telephone dialing system or device which  has the capacity to store or produce telephone numbers to be called using a random  or sequential number generator.   42.   The unwanted calls (i.e. text messages sent after opting out of the  Domino’s text message alert service) were made without the prior express consent  of the parties.   44.   Plaintiff incorporates Paragraphs 1 through 39.   45.    Defendant sent unwanted text messages to Plaintiff and the members  of the putative class using an automatic telephone dialing system or device which  has the capacity to store or produce telephone numbers to be called using a random  or sequential number generator.   46.   The unwanted calls (i.e. text messages sent after opting out of the  Domino’s text message alert service) were made without the prior express consent  of the parties.   NEGLIGENT VIOLATIONS OF THE  TELEPHONE CONSUMER PROTECTION ACT   WILLFUL VIOLATIONS OF THE  TELEPHONE CONSUMER PROTECTION ACT  