10.  On November 22,2016, Business Health Solutions received the unsolicited fax advertisement attached as Exhibit A on its facsimile machine.  The fax offered to purchase participation in a survey in exchange for a payment of $10.00.  11. Such faxes are advertisements subject to the TCPA. Fischbein v. Olson Research Grp., Inc., No. 19-3018, 2020 WL 2505178 (3d Cir. May 15, 2020).  12. Discovery may reveal the transmission of additional faxes as well.   13. Defendants are responsible for sending or causing the sending of the fax.  14. Defendants derived economic benefit from the sending of the fax.  15. Defendants either negligently or wilfully violated the rights of  Plaintiff and  other recipients in sending the fax.  16. Plaintiff had no prior relationship with Defendants and had not authorized the sending of fax advertisements to Plaintiff.  17. On information and belief, the fax attached hereto was sent as part of a mass broadcasting of faxes.  18. On information and belief, Defendants have transmitted similar unsolicited fax advertisements to at least 40 other persons in Michigan.  20. Plaintiff incorporates ¶¶ 1-19.  21. The TCPA makes unlawful the “use of any telephone facsimile machine, computer or other device to send an unsolicited advertisement to a telephone facsimile machine ...” 47 U.S.C. §227(b)(1)(C).  22. The TCPA,  47 U.S.C. §227(b)(3), provides: Private right of action. A person or entity may, if otherwise permitted by the laws or rules of court of a State, bring in an appropriate court of that State– (A)  an action based on a violation of this subsection or the regulations prescribed under this subsection to enjoin such violation, (B)  an action to recover for actual monetary loss from such a violation, or to receive $500 in damages for each such violation, whichever is greater, or (C)  both such actions. If the Court finds that the defendant willfully or knowingly violated this subsection or the regulations prescribed under this subsection, the court may, in its discretion, increase the amount of the award to an amount equal to not more than 3 times the amount available under the subparagraph (B) of this paragraph.  24. Plaintiff and each class member is entitled to statutory damages.  25. Defendants violated the TCPA even if their actions were only negligent.  26. Defendants should be enjoined from committing similar violations in the future. 27. Pursuant to Fed.R.Civ.P. 23(a) and (b)(3), Plaintiff brings this claim on behalf of a class, consisting of (a) all persons (b) who, on or after a date four years prior to the filing of this action (28 U.S.C. §1658), (c) were sent faxes by or on behalf of Research Now Group, LLC and/or  E-Rewards Services, Inc. offering payment in exchange for participation in a survey.  28. The class is so numerous that joinder of all members is impractical.  Plaintiff alleges on information and belief that there are more than 40 members of the class.  30. Plaintiff will fairly and adequately protect the interests of the class. Plaintiff has retained counsel experienced in handling class actions and claims involving unlawful business practices.  Neither Plaintiff nor Plaintiff's counsel have any interests which might cause them not to vigorously pursue this action.   31. Plaintiff’s claims are typical of the claims of the class members.  All are based on the same factual and legal theories.  32. A class action is the superior method for the fair and efficient adjudication of this controversy.  The interest of class members in individually controlling the prosecution of separate claims against Defendants is small because it is not economically feasible to bring individual actions. 