12. On or about July 2014, Defendant contacted Plaintiff on Plaintiff’s cellular  telephone number ending in “9642” via an automatic telephone dialing  system (“ATDS”) as defined by 47 U.S.C. § 277(a)(1), using an “artificial or  prerecorded voice” as prohibited by 47 U.S.C. § 277(b)(1)(A).   13. This ATDS has the capacity to store or produce telephone numbers to be  called using a random or sequential number generator.    14. Defendant utilized telephone number (855) 801-5775 to call Plaintiff on  Plaintiff’s cellular telephone.     15. At no time did Plaintiff enter into a business relationship with Defendant.   16. At no time did Plaintiff provide Plaintiff’s cellular telephone number ending  in “9642” to Defendant through any medium.   35. Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   36. The foregoing acts and omissions of Defendant constitute numerous and  multiple 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.   37. 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).   38. Plaintiff and the Class are also entitled to and seek injunctive relief  prohibiting such conduct in the future.  39. Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   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.  • As a result of Defendant’s negligent violations of 47 U.S.C. § 227(b)(1),  Plaintiff seeks for herself and each Class member $500.00 in statutory  damages, for each and every violation, pursuant to 47 U.S.C. §  227(b)(3)(B).  • Pursuant to 47 U.S.C. § 227(b)(3)(A), injunctive relief prohibiting such  conduct in the future.  • Any other relief the Court may deem just and proper. 