35.  Defendant is a company that sells solutions to improve personal  credit scores. During spring 2015 (starting in March 2015), in an effort to solicit  potential customers, Defendant began making telephone calls, en masse, to  consumers across the country. On information and belief Defendant and or its  agents purchase “leads” containing consumer’s contact information and creates  an electronic database from which Defendant makes automated calls.     36.  Defendant knowingly made these telemarketing calls without the  prior express written consent of the call recipients, and knowingly continue to  call them after requests to stop. As such, Defendant not only invaded the  personal privacy of Plaintiff and members of the putative Class, but also  intentionally and repeatedly violated the TCPA.  37.  On or about March 16, 2009 Plaintiff Carranza registered her  cellular phone number with the area code (619) and ending in 0058 with the  National Do Not Call Registry.   38.  Plaintiff Carranza is the regular carrier and exclusive user of the  telephone assigned the number ending in 0058.  The number is assigned to a  cellular telephone service for which Plaintiff Carranza is charged for incoming  calls pursuant to 47 U.S.C. § 227(b)(1).   39.  In the spring of 2015, Plaintiff Carranza began receiving calls on her  cellular telephone from the number (718) 509-9927, claiming to be Defendant,  CreditRepair.com     40.  Plaintiff Carranza never had a business relationship with Defendant.   Yet, she received at least 9 calls from Defendant.    51.  A Plaintiff’s injury must be both “concrete” and “particularized” in  order to satisfy the requirements of Article III of the Constitution. Id.    52.  For an injury to be concrete it must be a de facto injury, meaning it  actually exists.  In the present case, Plaintiff took the affirmative step of enrolling  herself on the National Do-Not-Call Registry for the purpose of preventing  marketing calls to their telephones. Such telemarketing calls are a nuisance, an  invasion of privacy, and an expense to Plaintiff. See Soppet v. enhanced  Recovery Co., LLC, 679 F.3d 637, 638 (7th Cir. 2012).  All three of these injuries  are present in this case. See also Chen, supra.   53.  Furthermore, the Third Circuit recently stated, Congress found that  “[u]nsolicited telemarketing phone calls or text messages, by their nature, invade  the privacy and disturb the solitude of their recipients,” Van Patten, 847 F.3d at  1043, and sought to protect the same interests implicated in the traditional  common law cause of action. Put differently, Congress was not inventing a new  theory of injury when it enacted the TCPA. Rather, it elevated a harm that, while  “previously inadequate in law,” was of the same character of previously existing  “legally cognizable injuries.” Spokeo, 136 S.Ct. at 1549. Spokeo addressed, and  approved, such a choice by Congress. Susinno v. Work Out World Inc., No. 16- 3277, 2017 WL 2925432, at *4 (3d Cir. July 10, 2017).   69.  Plaintiff hereby incorporates by reference and re-alleges each and  every allegation set forth in each and every preceding paragraph of this  Complaint, as though fully set forth herein.   70.  47 U.S.C. § 227(c) provides that any “person who has received  more than one telephone call within any 12-month period by or on behalf of the  same entity in violation of the regulations prescribed under this subsection may”  bring a private action based on a violation of said regulations, which were  promulgated to protect telephone subscribers’ privacy rights to avoid receiving  telephone solicitations to which they object.    75.  Plaintiff hereby incorporates by reference and re-alleges each and  every allegation set forth in each and every preceding paragraph of this  Complaint, as though fully set forth herein.   DNC CLAIM IN VIOLATION OF THE TELEPHONE CONSUMER PROTECTION ACT,   47 U.S.C. § 227, ET SEQ. (64 C.F.R. § 64.1200(C))  (By Plaintiff Against All Defendants)   INTERNAL DNC CLAIM IN VIOLATION OF   THE TELEPHONE CONSUMER PROTECTION ACT,   47 U.S.C. § 227, ET SEQ. (64 C.F.R. § 64.1200(D))  (By Plaintiff Against All Defendants)  