24.  Defendant Ehealth, Inc. is an online health insurance broker.  Around the period  Obamacare went into effect, Ehealth seized on the opportunity to offer Medicare options to eligible  consumers.  In an effort to solicit potential customers, Defendant recruited, or employed call  centers who began making telephone calls, en masse, to consumers across the country as early as  2015. On information and belief, Defendant and or its agents purchase “leads” containing  consumers’ contact information and create electronic databases from which Defendant and or its  agents makes automated calls.     27.  On or about January 21, 2014, Plaintiff registered her cellular phone number with  the area code (972) and ending in 0183 with the National Do Not Call Registry.   28.  During February 2016, Plaintiff began to receive calls on her cellular telephone  from the number (888) 353-4202, offering health insurance options.     29.  Plaintiff is the regular carrier and exclusive user of the telephone assigned the  number ending in 0183.  The number is assigned to a cellular telephone service for which Plaintiff  is charged for incoming calls pursuant to 47 U.S.C. § 227(b)(1).   30.  Plaintiff never had a business relationship with Defendant.   31.  Plaintiff never provided Defendant with prior consent to contact her on her phone  via a text message or a telephone call.   32.  Nonetheless, Defendant called Plaintiff dozens of times on her phone during a  twelve-month period.  Defendant always attempted to sell Plaintiff health insurance.     43.  Plaintiff has standing to bring this suit on behalf of herself and the members of the  class under Article III of the United States Constitution because Plaintiff’s claims states: (a) a valid  injury in fact; (b) an injury which is traceable to the conduct of Defendant; and (c) is likely to be  redressed by a favorable judicial decision.  See Spokeo v. Robins, 578 U.S. __ (2016) at 6; Robins  v. Spokeo, 867 F.3d 1108 (9th Cir. 2017) (cert denied. 2018 WL 491554, U.S., Jan. 22 2018);  Lujan v. Defenders of Wildlife, 504 U.S. 555, 560 (1992); and Chen v. Allstate Inc. Co., 819 F.3d  1136 (9th Cir. 2016).    44.  Plaintiff’s injury must be both “concrete” and “particularized” in order to satisfy  the requirements of Article III of the Constitution.  (Id.)    52.  Plaintiff brings this action pursuant to Federal Rule of Civil Procedure 23(a), (b)(2),  and (b)(3) on behalf of themselves and the following class defined as follows (the “Class”):  “DNC2 Class”: All individuals in the United States who: (1) received more  than one telephone call made by or on behalf of Defendant within a 12- month period; (2) to a telephone number that had been registered with the  National Do Not Call Registry for at least 30 days.    72.  Plaintiff re-alleges and incorporates by reference each preceding paragraph as  though set forth at length herein.   73.  47 U.S.C. § 227(c) provides that any “person who has received more than one  telephone call within any 12-month period by or on behalf of the same entity in violation of the  regulations prescribed under this subsection may” bring a private action based on a violation of  said regulations, which were promulgated to protect telephone subscribers’ privacy rights to avoid  receiving telephone solicitations to which they object.    74.  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 her 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.” See 47 C.F.R. § 64.1200(c).   A.  CLASS ALLEGATIONS   VIOLATION OF TCPA, 47 U.S.C. § 227  (“DNC Claim”)  