(Knowing and/or Willful Violations of the Telephone Consumer Protection  Act, 47 U.S.C. § 227(b)(1)(A))   (Violations of the Telephone Consumer Protection Act, 47 U.S.C. §  227(b)(1)(A))   18.  Defendant is a company that sells electronic payment services to  businesses.   19.  One of Defendant’s strategies for marketing its services and  generating new customers is telemarketing.   20.  Defendant’s strategy for generating new customers involves the use of  an automatic telephone dialing system (“ATDS”) to solicit business.   21.  Defendant uses ATDSs that have the capacity to store or produce  telephone numbers to be called.   22.  Defendant’s ATDSs include predictive dialers.   23.  Recipients of these calls, including Plaintiff, did not consent to receive  them.   24.  Plaintiff is, and at all times mentioned herein was, a “person” as  defined by 47 U.S.C. § 153(39).  The Automated Telemarketing Call From Defendant to a Number Listed on the  National Do Not Call Registry   50.  Plaintiff realleges and incorporates by reference each and every  allegation set forth in the preceding paragraphs.   54.  Plaintiff realleges and incorporates by reference each and every  allegation set forth in the preceding paragraphs.   55.  As a result of knowing and/or willful violations of the TCPA, 47  U.S.C. § 227(b)(1)(A), by Defendant, its affiliates or agents, and/or other persons  or entities acting on its behalf, Plaintiff and members of the Class are entitled to  treble damages of up to $1,500 for each and every call made to their cellular  telephone numbers using an ATDS and/or artificial or prerecorded voice in  violation of the statute. 47 U.S.C. § 227(b)(3).  IX. 