23.  Plaintiffs bring this action individually and on behalf of all others  similarly situated, as a member of the four proposed classes (hereafter, jointly, “The  Classes”).    24.  The class concerning the ATDS claim for no prior express consent  (hereafter “The ATDS Class”) is defined as follows:  All persons within the United States who received any  solicitation/telemarketing  telephone  calls  from  Defendant to said person’s cellular telephone made  through the use of any automatic telephone dialing  system or an artificial or prerecorded voice and such  person had not previously consented to receiving such  calls within the four years prior to the filing of this  Complaint   9.  Beginning on or around September 5, 2017, and continuing through  December of 2017, Defendant contacted Plaintiff Abante on Plaintiff Abante’s  cellular telephone numbers ending in -7511, -1636, -7210, -0106, -7447, -1080,  and -3803 in an attempt to solicit Plaintiff Abante to purchase Defendant’s services.    Knowing and/or Willful Violations of the Telephone Consumer Protection  Act   47 U.S.C. §227(c)   As a result of Defendant’s willful and/or knowing violations of 47  U.S.C. §227(c)(5), Plaintiffs and the DNC Class members are entitled  to and request treble damages, as provided by statute, up to $1,500,  for each and every violation, pursuant to 47 U.S.C. §227(c)(5).    An order for injunctive relief prohibiting such conduct by Defendants  in the future.   Any and all other relief that the Court deems just and proper.   Knowing and/or Willful Violations of the Telephone Consumer Protection  Act   47 U.S.C. §227(b)   As a result of Defendant’s willful and/or knowing violations of 47  U.S.C. §227(b)(1), Plaintiffs and the ATDS Class and the ATDS  Revocation Class members are entitled to and request treble damages,  as provided by statute, up to $1,500, for each and every violation,  pursuant to 47 U.S.C. §227(b)(3)(B) and 47 U.S.C. §227(b)(3)(C).    An order for injunctive relief prohibiting such conduct by Defendants  in the future.   Any and all other relief that the Court deems just and proper.   Negligent Violations of the Telephone Consumer Protection Act  47 U.S.C. §227(b)   As a result of Defendant’s negligent violations of 47 U.S.C.  §227(b)(1), Plaintiffs and the ATDS Class and ATDS Revocation  members are entitled to and request $500 in statutory damages, for  each and every violation, pursuant to 47 U.S.C.  227(b)(3)(B).    An order for injunctive relief prohibiting such conduct by Defendants  in the future.   Any and all other relief that the Court deems just and proper. 