10.  Defendant used an “automatic telephone dialing system” as defined  by 47 U.S.C. § 227(a)(1) to place its call to Plaintiff seeking to solicit its services.    11.  Defendant contacted or attempted to contact Plaintiff from telephone  numbers 925-828-4049 and 813-489-9986, confirmed to be Defendant’s numbers.   12.  Defendant’s calls constituted calls that were not for emergency  purposes as defined by 47 U.S.C. § 227(b)(1)(A).   13.  During all relevant times, Defendant did not possess Plaintiff’s “prior  express consent” to receive calls using an automatic telephone dialing system or an  artificial or prerecorded voice on its cellular telephone pursuant to 47 U.S.C. §  227(b)(1)(A).   14.  These calls by Defendant, or its agents, violated 47 U.S.C. § 227(b)(1).  15.  Plaintiff brings this action individually and on behalf of all others  similarly situated, as a member the proposed class (“The Class”).    8.  Beginning on or about September 6, 2017, Defendant contacted  Plaintiff on Plaintiff’s cellular telephone numbers ending in -0106 and -5154, in an  attempt to solicit Plaintiff to purchase Defendant’s services.     9.  When Plaintiff answered the phone, it heard a long pause followed by  a clicking noise indicative of an automated telephone dialing system.    Knowing and/or Willful Violations of the Telephone Consumer Protection  Act   47 U.S.C. §227(b)  • As a result of Defendant’s willful and/or knowing violations of 47  U.S.C. §227(b)(1), Plaintiff and The Class members are entitled to  and request treble damages, as provided by statute, up to $1,500, for  each and every violation, pursuant to 47 U.S.C. §227(b)(3)(B) and 47  U.S.C. §227(b)(3)(C).   • Any and all other relief that the Court deems just and proper.   Respectfully Submitted this 16th Day of October, 2020. 