11.  On May 11, 2015, Defendant sent an unsolicited advertisement to Plaintiffs ink- and-paper facsimile machine. The fax advertises services offered by Healthcare Data Solutions- which is owned completely by IMS Health Incorporated. A copy of this facsimile is attached  hereto and marked as Exhibit A.   12.  Exhibit A is exemplary of the junk faxes Defendant sends.   13.  Upon information and belief, Plaintiff has received multiple fax advertisements  from Defendant similar to Exhibit A. Indeed, between March 21, 2016 and June 15, 2016,  Defendant sent at least 5 additional unsolicited faxes to Plaintiffs ink-and-paper facsimile  machines. See attached Exhibit B, a compilation of 5 faxes sent to Plaintiff by Defendant. Upon  information and belief, Plaintiff has received hundreds of additional fax advertisements from  Defendant similar to Exhibit A.   14.  Defendant did not have Plaintiffs prior express invitation or permission to send  advertisements to Plaintiffs fax machine.   15.  Defendant's faxes do not contain opt-out notices that comply with the  requirements of the TCP A.  17.  Plaintiff reserves the right to modify or amend the definition of the proposed  Class before the Court determines whether certification is proper, as more information is gleaned  in discovery.   18.  Excluded from the Class are Defendant, any parent, subsidiary, affiliate, or  controlled person of Defendant, as well as the officers, directors, agents, servants, or employees  of Defendant and the immediate family members of any such person. Also excluded are any  judge who may preside over this case and any attorneys representing Plaintiff or the Class.   19.  Numerosity [Fed R. Civ. P. 23(a)(l)]. The Members of the Class are so numerous  that joinder is impractical. Upon information and belief, Defendant has sent illegal fax  advertisements to hundreds if not thousands of other recipients.   21.  Typicality [Fed. R. Civ. P. 23(a)(3)]. Plaintiffs claims are typical of the claims  of all Class Members. Plaintiff received an unsolicited fax advertisement from Defendant during  the Class Period. Plaintiff makes the same claims that it makes for the Class Members and seeks  the same relief that it seeks for the Class Members. Defendant has acted in the same manner  toward Plaintiff and all Class Members.   22.  Fair and Adequate Representation [Fed. R. Civ. P. 23(a)(4)]. Plaintiff will fairly  and adequately represent and protect the interests of the Class. It is interested in this matter, has  no conflicts, and has retained experienced class counsel to represent the Class.  