11.  On or about January 8, 2020, Defendants began using Plaintiff’s cellular telephone  (501-XXX-X856)2 for the purposes of sending Plaintiff political messages via mobile messaging  services and sent a text message again on January 9, 2020, and January 10, 2020.    12.  On or about January 13, 2020, Plaintiff texted “STOP” to 866-201-1348.   13.  On or about February 17, 2020, Plaintiff received a text from 833-676-4569 with  the words “FIFTH AND FINAL NOTICE: Your deadline to support President Trump has been  extended to 11:59PM and you are ELIGIBLE for 5x-matched support.  http://bit.ly/Fifth5X.”   14.  Plaintiff received at least four (4) texts from Defendants, with at least one text being  sent to her after she texted “STOP” to the January 10, 2020 text message. Those texts are attached  as Exhibit A to this complaint.   15.  The text messages were sent from phone numbers 1-(866) 201-1348 and 1-(833)  676-4599.   16.  When dialing back the number above, one is greeted with an automated voice that  states “the number you’ve dialed cannot be completed as dialed.” The call is then automatically  disconnected. Such an automated response is indicative of technology that constitutes an  “automatic telephone dialing system,” (“ATDS”) as defined by 47 U.S.C. § 227(a)(1) and  prohibited by 47 U.S.C. § 227(b)(1)(A).   18.  The text messages placed to Plaintiff’s cellular telephone were placed 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).   19.  The telephone number that Defendants, or its agent messaged was assigned to a  cellular telephone service for which Plaintiff incurs a charge for incoming calls pursuant to 47  U.S.C. § 227(b)(1).   20.  These text messages constituted calls that were not for emergency purposes as  defined by 47 U.S.C. § 227(b)(1)(A).   21.  As of January 8, 2020, Plaintiff did not provide Defendants or its agents with prior  express consent to receive unsolicited text messages, pursuant to 47 U.S.C. § 227(b)(1)(A).   22.  These messages by Defendants, or its agents, violated 47 U.S.C. § 227(b)(1).   23.  As a direct and proximate result of Defendants’ careless, negligent, intentional and  reckless conduct, as described more fully herein, Defendants are directly and affirmatively liable  for the serious and permanently disabling injuries suffered by the Plaintiff, for which she seeks  compensation in excess of the amount required for federal diversity jurisdiction.  VI.  24.  Plaintiff brings this action on behalf of herself and on behalf of all others similarly  situated in (“the Class”).   25.  Plaintiff represents, and is a member of the Class, consisting of all persons within  the United States who received any unsolicited text messages and/or any other unsolicited text  messages from Defendants without prior express consent.   27.  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 unsolicited text message,  thereby causing Plaintiff and the Class members to incur certain cellular telephone charges,  reduced battery life, or reduced 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.   28.  This suit seeks only damages and injunctive relief for recovery of economic injury  on behalf of the Class, and it expressly is not intended to request any recovery for personal injury  and claims related thereto. Plaintiff reserves the right to expand the Class definition to seek  recovery on behalf of additional persons as warranted as facts are learned in further investigation  and discovery.   29.  The joinder of the Class members is impractical and the disposition of their claims  in the Class action will provide substantial benefits both to the parties and to the court. The Class  can be identified through Defendants’ records or Defendants’ agents’ records.   31.  As a person that received at least one unsolicited text message without Plaintiff’s  prior express consent, Plaintiff is asserting claims that are typical of the Class. Plaintiff will fairly  and adequately represent and protect the interests of the Class in that Plaintiff has no interests  antagonistic to any member of the Class.   32.  Plaintiff and the members of the Class have all suffered irreparable harm as a result  of the Defendant’s unlawful and wrong conduct. Absent a class action, the Class will continue to  face the potential for irreparable harm. In addition, these violations of law will be allowed to  proceed without remedy and Defendants will likely continue such illegal conduct. Because of the  size of the individual Class member’s claims, few, if any, Class members could afford to seek legal  redress for the wrongs complained of herein.    33.  Plaintiff has retained counsel experienced in handling class action claims and  claims involving violations of the Telephone Consumer Protection Act.   35.  Defendants have acted on grounds generally applicable to the Class, thereby  making appropriate final injunctive relief and corresponding declaratory relief with respect to the  Class as a whole.  36.  Plaintiff incorporates by reference all of the above paragraphs of this Complaint as  though fully stated herein.   37.  The foregoing acts and omissions of Defendants constitute numerous and multiple  negligent 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.   38.  As a result of Defendants’ negligent violations of 47 U.S.C. § 227 et seq., Plaintiff  and the Class are entitled to an award of $500.00 in statutory damages, for each and every violation,  pursuant to 47 U.S.C. § 227(b)(3)(B).   39.  Plaintiff and the Class are also entitled to and seek injunctive relief prohibiting such  conduct in the future.  41.  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.   42.  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)(C).    43.  Plaintiff and the Class are also entitled to and seek injunctive relief prohibiting such  conduct in the future.  IX.  51.  As a result of Defendants’ negligent violations of 47 U.S.C. § 227(b)(1), Plaintiff  seeks for herself and each Class member $500.00 in statutory damages, for each and every  violation, pursuant to 47 U.S.C. § 227(b)(3)(B).   52.  Pursuant to 47 U.S.C. § 227 (b)(3)(A), injunctive relief prohibiting such conduct in  the future.   53.  Any other relief the Court may deem just and proper.  54.  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)(C).   55.  Pursuant to 47 U.S.C. § 227(b)(3)(A), injunctive relief prohibiting such conduct in  the future.   9.  At all times relevant, Plaintiff was a citizen of the State of Arkansas. Plaintiff is,  and at all times mentioned herein was, a “person” as defined by 47 U.S.C. § 153(10).   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.   TCPA, 47 U.S.C. § 227 ET SEQ.   VIOLATIONS OF THE TCPA, 47 U.S.C. § 227 ET SEQ.  