11.  Plaintiff was at all times mentioned herein the subscriber of the cellular telephone  number (954) ***-3307 (the “3307 Number”). The 3307 Number was at all times mentioned herein  assigned to a cellular telephone service as specified in 47 U.S.C. § 227(b)(1)(A)(iii).    12.  On or about April 8, 2019, Defendant transmitted or caused to be transmitted, by  itself or through an intermediary or intermediaries, an automated text message offering its “gig  economy,” courier-connection services to the 3307 Number without first obtaining Plaintiff’s prior  express consent or prior express written consent, and without providing Plaintiff a mechanism to  stop receiving such messages in the future.   24.  Class Definition. Plaintiff brings this civil class action on behalf of himself  individually and on behalf of all other similarly situated persons as a class action pursuant to  Federal Rule of Civil Procedure 23. The “Class” which Plaintiff seeks to represent is comprised  of and defined as:   All persons in the United States who, at any time between July 25,  2015 and the present, received one or more text message(s) from  Postmates, Inc. (or an affiliate, subsidiary, or agent of Postmates,  Inc.) and for whom Postmates, Inc. does not have a record of the  requisite consent to be sent such text messages.  