10.  Defendant MOHELA is generally engaged in the debt collection  business and conducts debt collection activities on a nationwide basis.   11.  Plaintiff owes no debt to any creditor associated with Defendant  MOHELA whatsoever.   12.  Sometime in or before July 2015, however, Defendant MOHELA began  making collection calls to Plaintiff’s cellular telephone.    13.  Defendant MOHELA placed collection calls to Plaintiff’s cellular  telephone at phone number ending in “1030.”     14.  Per its business practices, each of Defendant MOHELA’s calls were  placed using an “automatic telephone dialing system” (“ATDS”), as defined by 47  U.S.C. § 227(a)(1) and/or with an artificial or prerecorded voice, as prohibited by 47  U.S.C. § 227(b)(1)(A).    15.  At no time did Plaintiff consent, express or implied, to receive such  unsolicited telephone calls from Defendant.     16.  Through the unsolicited telephone calls, Defendant MOHELA contacted  Plaintiff’s cellular telephone for debt collection purposes via an ATDS and/or  artificial or pre-recorded voice as defined by 47 U.S.C. § 227(a)(1) and prohibited by  47 U.S.C. § 227(b)(1)(A).   17.  Upon information and belief, the ATDS used by Defendant MOHELA to  call Plaintiff has the capacity to store or produce telephone numbers to be called,  using a random or sequential number generator.    18.  The telephone number Defendant MOHELA called was assigned to  cellular telephones service for which Plaintiff incurs a charge for incoming calls  pursuant to 47 U.S.C. § 227(b)(1).     26.  Plaintiff brings this action on behalf of themselves and on behalf of all  other similarly situated (“the Class”).   47.  Plaintiff re-alleges the foregoing paragraphs as if fully set forth herein.   48.  The forgoing acts and omissions of Defendant constitute numerous and  multiple negligent violations of the TCPA, including but not limited to each and  everyone one of the above-cited provisions of 47 U.S.C. § 227, et seq.   49.  As a result of Defendant’s negligent violations of 47 U.S.C. § 227 et  seq., Plaintiff and the Class are entitled to an award of $500.00 in statutory damages,  for each and every violation, pursuant to 47 U.S.C. § 227(b)(3)(B).   51.  Plaintiff re-alleges the foregoing paragraphs as if fully set forth herein.   52.  The forgoing acts and omissions of Defendants constitute numerous and  multiple knowing and/or willful violations of the TCPA, including but not limited to  each and everyone one of the above-cited provisions of 47 U.S.C. § 227, et seq.   53.  As a result of Defendant’s knowing and/or willful violations of 47  U.S.C. § 227 et seq., Plaintiff and the Class are entitled to an award of up to  $1,500.00 in statutory damages, for each and every violation, pursuant to 47 U.S.C. §  227(b)(3)(B) and 47 U.S.C. § 227(b)(3)(C).   54.  Plaintiff and the Class are also entitled to and seek injunctive relief  prohibiting such conduct in the future.   Knowing and/or Willful Violations of the TCPA  (Against all Defendants)   Negligent Violations of the TCPA  (Against all Defendants)  