25.  On or about August 11, 2018, Defendant caused the following automated text message  to be transmitted to Plaintiff’s cellular telephone number ending in 9808 (“9808 Number”):   27.  The Website provides marketing information such as the “benefits of cannabidiol” and  contains a “RUSH MY ORDER NOW” and “GET MY BOTTLE” button to purchase Defendants  products.    30.  The Check-Out Page also includes the following contact information for the seller of  the products:  5   31.  Upon information and belief, Defendant owns and/or operates the 646-649-2655  telephone number (“2655 Number”) provided on the Check-Out Page.   32.  Defendant’s principle executive office is located at 404 E 76th Street, PH-C, New York,  NY 10021, which is the contact address provided on the Check-Out Page.    33.  Upon information and belief, Defendant also owns and/or operates the website  www.naturamiraclesinc.com (“Natura Miracles Website”).    35.  Upon information and belief, Defendant caused similar text messages to be sent to  individuals residing within this judicial district.     36.  At no point in time did Plaintiff provide Defendant with her express consent to be  contacted with telemarketing text messages using an ATDS.    37.  Plaintiff is the subscriber and sole user of the 9808 Number.   39.  The number (410-200-503) that transmitted the text messages is operated by or on  behalf of Defendant.     40.  The number used by Defendant (410-200-503) is known as a “long code” a standard 9- digit code that enables Defendant to send SMS text messages en masse.     41.  Long codes work as follows: Private companies known as SMS gateway providers have  contractual arrangements with mobile carriers to transmit two-way SMS traffic. These SMS gateway  providers send and receive SMS traffic to and from the mobile phone networks' SMS centers, which  are responsible for relaying those messages to the intended mobile phone. This allows for the  transmission of a large number of SMS messages to and from a long code.   42.  To send the text messages, Defendant used a messaging platform that permitted  Defendant to transmit thousands of automated text messages without any human involvement.     43.  The platform utilized by Defendant has the current capacity or present ability to generate  or store random or sequential numbers or to dial sequentially or randomly at the time the call is made,  and to dial such numbers, en masse, in an automated fashion without human intervention.   45.  Plaintiff brings this case as a class action pursuant to Fed. R. Civ. P. 23, on behalf of  herself and all others similarly situated.   46.  Plaintiff brings this case on behalf of the below defined Class:  All persons within the United States who, within the four  years prior to the filing of this Complaint, were sent a text  message using the same type of equipment, from  Defendant or anyone on Defendant’s behalf, to said  person’s  cellular  telephone  number,  advertising  Defendant’s services, without the recipients’ prior express  written consent.     47.  Defendant and their employees or agents are excluded from the Class. Plaintiff does not  know the number of members in the Class but believes the Class members number in the several  thousands, if not more.  51.  The common questions in this case are capable of having common answers. If Plaintiff’s  claim that Defendant routinely transmits text messages to telephone numbers assigned to cellular  telephone services is accurate, Plaintiff and the Class members will have identical claims capable of  being efficiently adjudicated and administered in this case.  56.  Plaintiff re-alleges and incorporates the foregoing allegations as if fully set forth  herein.    57.  It is a violation of the TCPA to make “any call (other than a call made for emergency  purposes or made with the prior express consent of the called party) using any automatic telephone  dialing system … to any telephone number assigned to a … cellular telephone service ….” 47 U.S.C. §  227(b)(1)(A)(iii).    58.  Defendant – or third parties directed by Defendant – used equipment having the capacity  to dial numbers without human intervention to make non-emergency telephone calls to the cellular  telephones of Plaintiff and the other members of the Class defined below.    60.  Defendant has, therefore, violated § 227(b)(1)(A)(iii) of the TCPA by using an  automatic telephone dialing system to make non-emergency telephone calls to the cell phones of  Plaintiff and the other members of the putative Class without their prior express written consent.   61.  Defendant knew that it did not have prior express consent to make these calls and knew  or should have known that it was using equipment that at constituted an automatic telephone dialing  system. The violations were therefore willful or knowing.    62.  As a result of Defendant’s conduct and pursuant to § 227(b)(3) of the TCPA, Plaintiff  and the other members of the putative Class were harmed and are each entitled to a minimum of $500.00  in damages for each violation. Plaintiff and the class are also entitled to an injunction against future  calls. Id.    PROPOSED CLASS   Violations of the TCPA, 47 U.S.C. § 227(b)  (On Behalf of Plaintiff and the Class)  