11. Plaintiff is, and at all times mentioned herein was, “persons” as defined by 47  U.S.C § 153 (39).   12. Defendant is, and at all times mentioned herein was, a “person” as defined by  35. Plaintiff brings this action on behalf of himself and on behalf of all others  similarly situated (“the Class”).   47. Plaintiff incorporates by reference all of the above paragraphs of this Com- plaint as though fully stated herein.   48. The foregoing acts and omissions of Defendant constitute numerous and mul- tiple negligent violations of the TCPA, including but not limited to each and  every one of the above-cited provisions of 47 U.S.C. § 227 et seq.   49. As a result of Defendant’ negligent violations of 47 U.S.C. § 227 et seq.,  Plaintiff and the Class are entitled to an award of $500.00 in statutory dam- ages, for each and every violation, pursuant to 47 U.S.C. § 227(b)(3)(B).   51. Plaintiff incorporates by reference all of the above paragraphs of this Com- plaint as though fully stated herein.   52. The foregoing acts and omissions of Defendant constitute numerous and mul- tiple knowing and/or willful violations of the TCPA, including but not lim- ited to each and every one of the above-cited provisions of 47 U.S.C. § 227 et  seq.   53. As a result of Defendant’ knowing and/or willful violations of 47 U.S.C. §  227 et seq., Plaintiff and each of the Class are entitled to treble damages, as  provided by statute, up to $1,500.00, 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 prohibit- ing such conduct in the future.  56. As a result of Defendant’ negligent violations of 47 U.S.C. § 227(b)(1),  Plaintiff seeks  for  himself and each Class member $500.00 in statutory  damages, for each and every violation, pursuant to 47 U.S.C. § 227(b)(3)(B).   57. Pursuant to 47 U.S.C. § 227(b)(3)(A), injunctive relief prohibiting such con- duct in the future.   59. As a result of Defendant’ willful and/or knowing violations of 47 U.S.C. §  227(b)(1), Plaintiff seeks for himself and each Class member treble damages,  as provided by statute, up to $1,500.00 for each and every violation, pursuant  to 47 U.S.C. § 227(b)(3)(B) and 47 U.S.C. § 227(b)(3)(C).   60. Pursuant to 47 U.S.C. § 227(b)(3)(A), injunctive relief prohibiting such con- duct in the future.   61. Any other relief the Court may deem just and proper.  KNOWING AND/OR WILLFUL VIOLATIONS OF THE TELEPHONE  CONSUMER PROTECTION ACT 47 U.S.C. § 227 ET SEQ.   NEGLIGENT VIOLATIONS OF THE TELEPHONE CONSUMER  PROTECTION ACT 47 U.S.C. § 227 ET SEQ.   THE TCPA, 47 U.S.C. § 227 ET SEQ.   VIOLATION OF THE TCPA, 47 U.S.C. § 227 ET SEQ.  