13.  Texts sent by or on behalf of Nations Info are solicitations for Nations Info’s rent- to-own membership services.    48.  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 class certification (1) Defendant (or  an agent acting on behalf of Defendant) placed text message calls, (2) to the  person’s cellular telephone number, (3) using the text messaging platform  Defendant used to place text message calls to Plaintiff, (4) for whom Defendant  claims it obtained prior express consent in the same manner as Defendant claims it  supposedly obtained prior express consent to text message Plaintiff.  Do Not Call Registry Class: All persons in the United States who from four years  prior to the filing of this action through class certification (1) Defendant (or an agent  acting on behalf of Defendant) texted more than one time; (2) within any 12-month  period (3) where the person’s telephone number had been listed on the DNC for at  least thirty days; (4) for the same reason that Defendant texted Plaintiff; and (5) for  whom Defendant claims it obtained prior express consent in the same manner as  Defendant claims it supposedly obtained prior express consent to text message  Plaintiff.   54.  Plaintiff repeats and realleges paragraphs 1 through 52 of this Complaint and  incorporates them by reference.   55.  Defendant and/or its agents sent unwanted solicitation text messages to cellular  telephone numbers belonging to Plaintiff and the other members of the Autodialed No Consent  Class using an autodialer.    56.  These solicitation text messages were sent en masse without the consent of the  Plaintiff and the other members of the Autodialed No Consent Class to receive such solicitation  text messages.   60.  Plaintiff repeats and realleges the paragraphs 1 through 52 of this Complaint and  incorporates them by reference.   61.  The TCPA’s implementing regulation, 47 C.F.R. § 64.1200(c), provides that “[n]o  person or entity shall initiate any telephone solicitation” to “[a] residential telephone subscriber  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 that is maintained by the federal government.”   62.  47 C.F.R. § 64.1200(e), provides that § 64.1200(c) and (d) “are applicable to any  person or entity making telephone solicitations or telemarketing calls to wireless telephone  numbers.”26   63.  47 C.F.R. § 64.1200(d) further provides that “[n]o person or entity shall initiate  any call for telemarketing purposes to a residential telephone subscriber unless such person or  entity has instituted procedures for maintaining a list of persons who request not to receive  telemarketing calls made by or on behalf of that person or entity.”   Class Treatment Is Appropriate for Plaintiff’s TCPA Claims    Nations Info Markets its Products by Placing, or Having Placed  On its Behalf Unsolicited Text Messages   Telephone Consumer Protection Act  (Violations of 47 U.S.C. § 227, et. seq.)  (On Behalf of Plaintiff and the Autodial No Consent Class)   Telephone Consumer Protection Act  (Violation of 47 U.S.C. § 227, et. seq.)  (On Behalf of Plaintiff and the Do Not Call Registry Class)  