15.  When placing calls to consumers, Reliant Direct agents identify themselves either  as Reliant Direct, an eFinancial partner, or directly as eFinancial.   16.  When Plaintiff answered a call, or called Reliant Direct, he was told that he was  dealing with eFinancial.   17.  According to the Utah Insurance Department, John Paraiso, the owner of Reliant  Direct is an agency affiliate of Defendant eFinancial:  3  The California Department of Insurance also shows that Paraiso has an agency affiliation with   eFinancial:  4   18.  As the California Department of Insurance shows in the image above, Paraiso is  authorized to transact business only on behalf of eFinancial.  eFinancial Directs, Authorizes, and/or Ratifies the Unlawful   Telemarketing Conduct Reliant Direct Engages in to Solicit New Business   19.  eFinancial receives payment for each life insurance plan Reliant Direct sells.   37.  On July 28, 2018, Plaintiff registered his cellular telephone number on the DNC  in order to avoid receiving unwanted calls.   51.  Plaintiff brings this action pursuant to Federal Rule of Civil Procedure 23(b)(2)  and Rule 23(b)(3) on behalf of himself and all others similarly situated and seeks certification of  the following four Classes:  Autodialed No Consent Class: All persons in the United States who from four  years prior to the filing of this action (1) Defendant Reliant Direct called on  behalf of eFinancial, (2) on the person‟s cellular telephone number, (3) using the  same dialing equipment used to call Plaintiff and (4) for whom either Defendant  claims (a) it obtained prior express written consent in the same manner as either  Defendant claims it obtained prior express written consent to call Plaintiff, or (b)  the Defendants did not obtain prior express written consent.  Do Not Call Registry Class: All persons in the United States who from four  years prior to the filing of this action (1) Defendant Reliant Direct called on  behalf of eFinancial, (2) on the person‟s residential telephone number, (3) two or  more times during any twelve month period, and (4) for whom either Defendant  claims (a) it obtained prior express written consent in the same manner as either  Defendant claims it obtained prior express written consent to call Plaintiff, or (b)  the Defendants did not obtain prior express written consent.  Internal Do Not Call Registry Class: All persons in the United States who from  four years prior to the filing of this action (1) Defendant Reliant Direct called on  behalf of eFinancial, (2) on the person‟s residential telephone number, (3) two or  more times during any twelve month period.    57.  Plaintiff repeats and realleges paragraphs 1 through 56 of this Complaint and  incorporates them by reference herein.   58.  Reliant Direct and/or its agents made unwanted solicitation telephone calls to  cellular telephone numbers belonging to Plaintiff and the other members of the Autodialed No  Consent Class using an autodialer on behalf of eFinancial.    62.  Plaintiff repeats and realleges the paragraphs 1 through 56 of this Complaint and  incorporates them by reference herein.   63.  The TCPA‟s implementing regulation, 47 C.F.R. § 64.1200(c), provides that “[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.”   64.  47 C.F.R. § 64.1200(e), provides that § 64.1200(c) is “applicable to any person or  entity making telephone solicitations or telemarketing calls to wireless telephone numbers.”9   69.  Plaintiff Jones repeats and realleges paragraphs 1 through 56 of this Complaint  and incorporates them by reference herein.   Class Treatment Is Appropriate for Plaintiff’s TCPA Claims    Reliant Direct Agents Repeatedly Called Plaintiff’s Cell Phone Number Without Plaintiff’s  Consent, Despite Plaintiff Registering His Phone Number on the DNC   Reliant Direct Markets Life Insurance Plans Exclusively on Behalf of Defendant eFinancial   Telephone Consumer Protection Act  (Violations of 47 U.S.C. § 227)  (On Behalf of Plaintiff Jones and the Autodialed No Consent Class)   Telephone Consumer Protection Act  (Violation of 47 U.S.C. § 227)  (On Behalf of Plaintiff Jones and the Do Not Call Registry Class)   Telephone Consumer Protection Act   (Violation of 47 U.S.C. § 227)  (On Behalf of Plaintiff Jones and the Internal Do Not Call Class)  