12.  Shortly after the creation of the National Do Not Call Registry in 2003, Mr. Chinitz  placed his landline number (831-420-####) on the Registry. In or around 2015, Mr. Chinitz placed a  VOIP line (408-501-####) on the National Do Not Call Registry. In or around June 2017, Mr. Chinitz  re-registered both numbers, under the mistaken impression that his original registration had expired.   13.  On or around May 17, 2017, Mr. Chinitz, though his real estate agent, Katy Cowley,  listed his home in Santa Cruz, California, for sale.    14.  Ms. Cowley placed the listing on an online real estate listing portal, Multiple Listing  Service (“MLS”).   15.  The MLS listing for Mr. Chinitz’s home expired on November 1, 2017.     16.  The listing included a private instruction to real estate agents that read, “OWNERS  39.  Plaintiff brings this action on behalf of himself and a class of all others similarly situated  pursuant to Federal Rule of Civil Procedure 23.   51.  Plaintiff incorporates by reference all above paragraphs as though fully repeated herein.   52.  The TCPA 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. 47 U.S.C. § 227(c)(5).   53.  Under 47 C.F.R. § 64.1200(c)(2), “[n]o person or entity shall initiate any telephone  solicitation” to “[a] residential telephone subscriber who has registered his or her telephone number on  the national do-not-call registry of persons who do not wish to receive telephone solicitations that is  maintained by the federal government.”   54.  A caller is not liable for violating the TCPA if it can demonstrate that its violation “is  the result of error and that as part of its routine business practice, it meets the following standards:  (A) Written procedures. It has established and implemented written procedures to  comply with the national do-not-call rules;  (B) Training of personnel. It has trained its personnel, and any entity assisting in its  compliance, in procedures established pursuant to the national do-not-call rules;  (C) Recording. It has maintained and recorded a list of telephone numbers that the  seller may not contact;  (D) Accessing the national do-not-call database. It uses a process to prevent telephone  solicitations to any telephone number on any list established pursuant to the do-not- call rules, employing a version of the national do-not-call registry obtained from the  administrator of the registry no more than 31 days prior to the date any call is made,  and maintains records documenting this process.”  47 C.F.R. § 64.1200(c)(2)(i).    65.  Plaintiff incorporate by reference all above paragraphs as though fully repeated herein.   66.  The TCPA 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. 47 U.S.C. § 227(c)(5).   67.  Under 47 C.F.R. § 64.1200(d), “[n]o person or entity shall initiate any call for  telemarketing purposes to a residential telephone subscriber unless such person or entity has instituted  procedures for maintaining a list of persons who request not to receive telemarketing calls made by or  on behalf of that person or entity. The procedures instituted must meet certain minimum standards,  including:   “(3) Recording, disclosure of do-not-call requests. If a person or entity making a call  for telemarketing purposes (or on whose behalf such a call is made) receives a request  from a residential telephone subscriber not to receive calls from that person or entity,  the person or entity must record the request and place the subscriber’s name, if  provided, and telephone number on the do-not call list at the time the request is made.  Persons or entities making calls for telemarketing purposes (or on whose behalf  such calls are made) must honor a residential subscriber’s do-not-call request  within a reasonable time from the date such request is made. This period may  not exceed thirty days from the date of such request . . . .   (6) Maintenance of do-not-call lists. A person or entity making calls for telemarketing  purposes must maintain a record of a consumer’s request not to receive further  telemarketing calls. A do-not-call request must be honored for 5 years from the  time the request is made.”   47 C.F.R. § 64.1200(d)(3), (6) (emphasis added).   68.  Plaintiff and Class B members made requests to Defendants not to receive calls from  Defendants.    76.  Plaintiff incorporate by reference all above paragraphs as though fully repeated herein.   77.  The TCPA prohibits a caller from initiating any telephone call to a residential telephone  line using an artificial or prerecorded voice to deliver a message without the prior express consent of  the contacted party unless the call was initiated for emergency purposes, is made solely to collect a debt  owed or guaranteed by the United States or is exempted by a FCC rule or order.    78.  Defendants initiated multiple telephone calls using an artificial or prerecorded voice to  residential telephone lines to Plaintiff and other members of Class C.    85.  Plaintiff incorporate by reference all above paragraphs as though fully repeated herein.   86.  Defendants’ practices of initiating, or causing to be initiated, telephone solicitations to  residential telephone subscribers like Plaintiff and Class members who registered their respective  telephone numbers on the National Do Not Call Registry, failing to honor do not call requests, and  using an artificial or prerecorded message to initiate calls violate 47 U.S.C. § 227 et seq., and the  regulations promulgated under it.     Violation of Cal. Bus. & Prof. Code § 17200 et seq.  (On behalf of Plaintiff and All Classes)   Violation of 47 U.S.C. § 227(c)(2)  (On behalf of Plaintiff and Class B – National Internal Do Not Call Class)   Violation of 47 U.S.C. § 227(b)(1)(B)  (On behalf of Plaintiff and Class C - National Artificial or Prerecorded Message Class)   Violation of 47 U.S.C. § 227(c)(2)  (On behalf of Plaintiff and Class A - National Do Not Call Registry Class)  