12.  HealthMarkets	provides	its	agents	with	3	things	that	are	critical	to	the	sale	of	 HealthMarkets’	insurance	packages:	Training,	Technology	and	Leads.	 Training:   13.  HealthMarkets	provides	a	full	training	program	that	is	designed	to	prepare	 agents	to	make	sales.1	  14.  It	provides	agents	with	access	to	HealthMarkets	University	where	agents	 learn	business	plan	development,	receive	instructor-led	training	and	receive	ongoing	 coaching	and	mentorship.2	  15.  Upon	information	and	belief,	the	training	teaches	agents	how	to	place	cold	 calls	to	consumers.		  16.  HealthMarkets	even	provides	its	insurance	agents	with	call	scripts	that	 should	be	used	in	order	to	solicit	business	from	consumers.3		  29.  On December 6, 2008, Plaintiff registered his cellular telephone number on the  DNC in order to avoid receiving unsolicited calls and text messages.    30.  Plaintiff uses his cellular phone for personal use only. Plaintiff’s cellular phone  number is not associated with a business.   31.  On January 2, 2019 at 3:45 PM, Plaintiff received an unsolicited phone call to his  cellular phone from Defendant using phone number 720-925-9569. The call was not answered,  but a voicemail was left regarding booking an appointment with Lauren Taylor for an insurance  quote.    32.  After the voicemail was left on his cellular phone, Plaintiff received an autodialed  text message from Defendant to his cellular phone using phone number 720-925-9569 on  January 2, 2019 at 4:45 PM:   48.  Plaintiff repeats and realleges paragraphs 1 through 47 of this Complaint and  incorporates them by reference herein.   49.  Defendant and/or its agents placed unwanted solicitation calls and/or sent  unwanted solicitation text messages to cellular telephone numbers belonging to Plaintiff and the  other members of the Autodialed No Consent Class.    50.  These solicitation phone calls and text messages were sent en masse without the  consent of the Plaintiff and the other members of the Autodialed No Consent Class.   51.  Defendant has, therefore, violated 47 U.S.C. § 227(b)(1)(A)(iii). As a result of  Defendant’s conduct, Plaintiff and the other members of the Autodialed No Consent Class are  each entitled to, under 47 U.S.C. § 227(b)(3)(B), a minimum of $500.00 in damages for each  violation of such act.   52.  In the event that the Court determines that Defendant’s conduct was willful or  knowing, it may, under 47 U.S.C. § 227(b)(3)(C), treble the amount of statutory damages  recoverable by Plaintiff and the other members of the Autodialed No Consent Class.  53.  Plaintiff repeats and realleges the paragraphs 1 through 47 of this Complaint and  incorporates them by reference herein.   Class Treatment Is Appropriate for Plaintiff’s TCPA Claims   Arising From Calls and Texts Sent by HealthMarkets Agents   HealthMarkets is Responsible for the Telemarketing Calls Placed by Its Agents   Plaintiff Received Unwanted Autodialed Calls and Text Messages to His Cell Phone  Number, Despite Plaintiff Registering His Phone Number on the DNC    Telephone Consumer Protection Act  (Violation of 47 U.S.C. § 227)  (On Behalf of Plaintiff Declements and the Do Not Call Registry Class)   Telephone	Consumer	Protection	Act	 (Violations	of	47	U.S.C.	§	227)	 (On	Behalf	of	Plaintiff	and	the	Autodialed	No	Consent	Class)	 