16. On or about May 29, 2013 at approximately 6:20 p.m. PST, Defendants  contacted Plaintiff on Plaintiff’s cellular telephone number ending in 4164  via an “automatic telephone dialing system” (“ATDS”), as defined by 47  U.S.C. § 227(a)(1), as prohibited by 47 U.S.C. § 227(b)(1)(A).   17. This ATDS has the capacity to store or produce telephone numbers to be  called, using a random or sequential number generator.    18. On or about May 30, 2013 at approximately 3:10 p.m. PST, Defendants  again contacted Plaintiff on Plaintiff’s cellular telephone number via an  27. Plaintiff brings this action on behalf of herself and on behalf of all others  similarly situated (the “Class”).   28. Plaintiff represents, and is a member of the Class, consisting of:   All persons within the United States who received any  telephone call/s from Defendants or their agent/s and/or  employee/s to said person’s cellular telephone made  through the use of any automatic telephone dialing  system within the four years prior to the filing of the  Complaint.   29. Defendants and its 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.  Thus, this  matter should be certified as a Class action to assist in the expeditious  litigation of this matter.   30. Plaintiff and members of the Class were harmed by the acts of Defendants in  at least the following ways: Defendants, either directly or through their  agents, illegally contacted Plaintiff and the Class members via their cellular  telephones by using an ATDS, thereby causing Plaintiff and the Class  members to incur certain cellular telephone charges or reduce cellular  telephone time for which Plaintiff and the Class members previously paid,  and invading the privacy of said Plaintiff and the Class members.  Plaintiff  and the Class members were damaged thereby.   39. Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   43. Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   44. The foregoing acts and omissions of Defendants constitute numerous and  multiple knowing and/or willful 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.   45. As a result of Defendants’ knowing and/or willful violations of 47 U.S.C. §  227 et seq., Plaintiff and the Class are entitled to an award of $1,500.00 in  statutory damages, for each and every violation, pursuant to 47 U.S.C. §  227(b)(3)(B) and 47 U.S.C. § 227(b)(3)(C).   46. Plaintiff and the Class are also entitled to and seek injunctive relief  prohibiting such conduct in the future.  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 Defendants’ knowing and/or willful violations of 47 U.S.C.  § 227(b)(1), Plaintiff seeks for herself and each Class member $1,500.00  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. 