14.  Defendant Safelife sells medical alert devices.   15.  Defendant Safelife hired Defendant John Doe to make robocalls promoting Safelife’s  products.   16.  To increase their sales and avoid paying for legitimate forms of advertising, John Doe  called and sent artificial and prerecorded voice messages to thousands of residential and cellular   telephones at a time.     17.  When the Class members answered their cell phones expecting to hear from a real person,  Defendants pulled a bait and switch by playing an artificial or prerecorded voice message.    18.  Unfortunately, Defendants failed to obtain consent from Plaintiff and the Class before  bombarding their cell phones with these illegal voice recordings.  28.  Class Definition: Plaintiff brings this action pursuant to Federal Rule of Civil Procedure  23(b)(2), and 23(b)(3) on behalf of Plaintiff and a class defined as follows:  TCPA Class.  All persons in the United States who: (1) from the last 4 years to  present (2) received at least one telephone call; (3) on his or her cellular or  residential telephone; (4) that was played an artificial or prerecorded voice  message; (5) for the purpose of promoting Defendants’ products   36.  Plaintiff incorporates the foregoing allegations as if fully set forth herein.   37.  Defendants and/or their agent placed telephone calls to Plaintiff’s and the Class  members’ cellular telephones without having their prior express written consent to do so.   38.  Defendants’ calls were made for a commercial purpose.   39.  Defendants played artificial or prerecorded voice message to the cellular and residential  phones of Plaintiff and the Class members as proscribed by 47 U.S.C. § 227(b)(1)(A)(iii) and (B).   40.  As a result of its unlawful conduct, Defendants repeatedly invaded Plaintiff’s and the  Class’s personal privacy, causing them to suffer damages and, under 47 U.S.C. § 227(b)(3)(B), entitling  them to recover $500 in civil fines for each violation and an injunction requiring Defendants to stop  their illegal calling campaign.   41.  Defendants and/or its agent made the violating calls “willfully” and/or “knowingly” under  47 U.S.C. § 227(b)(3)(C).   42.  If the court finds that Defendants willfully and/or knowingly violated this subsection, the  court may increase the civil fine from $500 to $1500 per violation under 47 U.S.C. § 227(b)(3)(C).  Violation of 47 U.S.C. § 227  (On behalf of Plaintiff and the Class)  