40. Plaintiff brings this action on behalf of himself and on behalf of all others  similarly situated (“the Class”).   41. Plaintiff represents, and is a member of the Class, consisting of: “all persons  within the United States who received a text message substantially similar or  identical to the text messages described above in this Complaint from  Defendant, which message by Defendant or its agents was not made for  emergency purposes, within the four years prior to the filing of this  Complaint.”   42. Defendant and its employees or agents are excluded from the Class. Plaintiff  does not know the number of members in the Class, but believes the Class  members number in the tens of thousands, if not more. Thus, this matter  should be certified as a Class action to assist in the expeditious litigation of  this matter.   43. Plaintiff and members of the Class were harmed by the acts of Defendant in at  least the following ways: Defendant, either directly or through its agents,  illegally contacted Plaintiff and the Class members via their cellular  telephones by using an unsolicited and impersonal form SPAM text messages,  thereby causing Plaintiff and the Class members to incur certain cellular  telephone charges or reduce cellular telephone time for which Plaintiff and the  Class members previously paid, and invading the privacy of said Plaintiff and  the Class members. Plaintiff and the Class members were damaged thereby.   51. Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   52. The foregoing acts and omissions of Defendant constitute numerous and  multiple negligent violations of the TCPA, including but not limited to each  and every one of the above-cited provisions of 47 U.S.C. § 227 et seq.   55. Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   56. The foregoing acts and omissions of Defendant constitute numerous and  multiple knowing and/or willful violations of the TCPA, including but not  limited to each and every one of the above-cited provisions of 47 U.S.C. §  227 et seq.   57. As a result of Defendant’s knowing and/or willful violations of 47 U.S.C. §  227 et seq., Plaintiff and The Class are entitled to an award of $1,500.00 in  statutory damages, for each and every violation, pursuant to 47 U.S.C. §  227(b)(3)(B) and 47 U.S.C. § 227(b)(3)(C).   58. Plaintiff and the Class are also entitled to and seek injunctive relief  prohibiting such conduct in the future.  62. As a result of Defendant’s knowing and/or willful violations of 47 U.S.C. §  227(b)(1), Plaintiff seeks for himself and each Class member $1,500.00 in  statutory damages, for each and every violation, pursuant to 47 U.S.C. §  227(b)(3)(B).   63. Pursuant to 47 U.S.C. § 227(b)(3)(A), injunctive relief prohibiting such  conduct in the future.   64. Any other relief the Court may deem just and proper.   65. KNOWING AND/OR WILLFUL VIOLATIONS OF THE TELEPHONE  CONSUMER PROTECTION ACT 47 U.S.C. § 227 ET SEQ.  NEGLIGENT VIOLATIONS OF THE TELEPHONE CONSUMER  PROTECTION ACT 47 U.S.C. § 227 ET SEQ.  TCPA, 47 U.S.C. § 227 ET SEQ.  VIOLATIONS OF THE TCPA, 47 U.S.C. § 227 ET SEQ. 