11.  Defendant is the distributor of Acura automobiles throughout the  United States.   13.  As an ordinary business practice, Defendant then makes automated  telephone calls to such customers to conduct surveys, solicit feedback and for  other commercial purposes.   14.  However, Defendant’s dealer network and administration  processes lack the procedures necessary to confirm that the telephone numbers  Defendant calls belong to consumers who have actually provided their consent  to receive Defendant’s automated telephone calls soliciting information.   15.  As a consequence, many of the telephone numbers in Defendant’s  automated calling database do not belong there, resulting in Defendant routinely  placing automated information solicitation calls to consumers who have never  provided their consent to receive such calls from Defendant.   16.  Defendant’s practice of making unauthorized robocalls to  consumers who did not consent to receive such calls is widespread and well- documented, as seen from just a few samples of the many complaints involving  robocalls placed by Defendant that have been publicly posted online:   “They keep calling.  It shows [A]cura, but no one answers.  I wait  15 seconds & hang up.  This is very annoying.”   “I do not own an Acura, but my boyfriend does and my phone  number is not associated with his car or account.  We just received  the call at the exact same time and don't understand why.”   “I also had my Acura serviced last week and a hang up call came  today.  Very unprofessional for Acura.”   “I believe I have had more than 10 calls from this number on my  CELL phone!  Fortunately, I figured out how to block this caller.  I  answered once, a young woman said she was from Acura.........and  I hung up.  I don't own an Acura.  I really hate these robo-calls.”   18.  Beginning in or about March 2015, Defendant began placing  unsolicited robocalls to Plaintiff’s cellular telephone after Plaintiff took his  Acura vehicle to a dealership for service.   19.  Indeed, on March 17, 2015 Plaintiff’s cell phone rang and  indicated that he was receiving a phone call from 410-774-8480, a phone  number Defendant routinely utilizes to place automated calls to consumers  soliciting information.   20.  Plaintiff received these unwanted and unsolicited robocalls several  more times over the following weeks.    21.  Upon information and belief, Defendant places calls, including the  calls made to Plaintiff, en masse using a “predictive” dialer, which  automatically places calls without human intervention until the called party  answers the call, at which time the automatic dialer attempts to connect the  called party with a human representative or an automated prompt.   22.   At no time did Plaintiff provide Defendant with consent to place  such robocalls to his cellular telephone number.  23.  Plaintiff brings this action on behalf of himself and a nationwide  class defined as follows:  All persons in the United States and its Territories to whom, within four  years prior to the commencement of this litigation, Defendant placed  through an automated telephone dialing system one or more unauthorized  calls soliciting information to their cellular telephones.   25.  Absent a class action, most members of the Class would find the  cost of litigating their claims to be prohibitive and would have no effective  remedy.  The class treatment of common questions of law and fact is superior to  multiple individual actions or piecemeal litigation in that it conserves the  resources of the courts and the litigants, and promotes consistency and  efficiency of adjudication.   26.  Defendant has acted and failed to act on grounds generally  applicable to the Plaintiff and the other members of the Class, requiring the  Court’s imposition of uniform relief to ensure compatible standards of conduct  toward the members of the Class, and making injunctive or corresponding  declaratory relief appropriate for the Class as a whole.    27.  The factual and legal bases of Defendant’s liability to Plaintiff and  to the other members of the Class are the same, resulting in injury to Plaintiff  and to all of the other members of the Class.  Plaintiff and the other members of  the Class have all suffered harm and damages as a result of Defendant’s  unlawful and wrongful conduct.   28.  Upon information and belief, there are hundreds, if not thousands,  of members of the Class such that joinder of all members is impracticable.   30.  Plaintiff incorporates by reference the foregoing allegations as if  fully set forth herein.   31.  Defendant made unsolicited telephone survey calls without prior  express consent using an automatic telephone dialing system to the cellular  telephone numbers of Plaintiff and the other members of the Class.  Each such  automated call was made using a predictive dialer, equipment that had the  capacity at the time the calls were placed to store or produce telephone numbers  to be called using a random or sequential number generator and to dial such  numbers without human intervention.   32.  Defendant’s  conduct  violated  the  Violation of the Telephone Consumer Protection Act (47 U.S.C. § 227)  on behalf of the Class   