19. Sundance operates as a travel company. On its website, Sundance claims to have  encouraged tens of thousands of clients to explore, dream and discover.  20. Unfortunately for consumers, Sundance utilizes a sophisticated telephone dialing  system to call consumers with pre-recorded messages en masse promoting its services.   However, Sundance fails to get the requisite prior consent prior to sending these text messages.  21. In Sundance overzealous attempt to market its services,  Defendant knowingly  made (and continues to make) telemarketing phone calls with pre-recorded messages without the  prior express written consent of the call recipients, and continued to send messages after requests  that the text messages stop.  As such, Sundance not only invaded the personal privacy of  Plaintiffs and members of the Classes, but also intentionally and repeatedly violated the TCPA. 22. At all times relevant hereto, Plaintiff was assigned, and was the owner of a cellular telephone number of 732-453-4197.    23. During and around March 2021, Defendant began calling Plaintiff on her cellular  telephone number via an ATDS and with a pre-recorded message, as defined by 47 U.S.C. §  227(a)(1).  25. On information and belief, and based on the circumstances as described above,  Defendant called Plaintiff using an ATDS and with pre-recorded messages.    26. When Plaintiff listened to the message, Plaintiff was able to determine that it was  a prerecorded message. See, Rahn v. Bank of Am., No. 1:15-CV-4485-ODE-JSA, 2016 U.S. Dist.  LEXIS 186171, at *10-11 (N.D. Ga. June 23, 2016) (“When one receives a call, it is a clear-cut  fact, easily discernible to any lay person, whether or not the recipient is speaking to a live human  being, or is instead being subjected to a prerecorded message.”).   27. That these voice messages were pre-recorded were evident from inter alia (a) the  fact that each of the pre-recorded voice messages received by the Plaintiff were exactly identical  in content, tone and inflection, without even the most minute variation between these messages,  (b) the generic content of the voice message, and (3) the tone, cadence and inflection of the voice  message, which sounded to the Plaintiff’s ears like a pre-recorded message, rather than a  personal voice message that was placed personally for the Plaintiff by an individual.   28. Plaintiff has previously received both pre-recorded voice messages and regular  non-prerecorded voice messages, and has experienced the different characteristics and sounds of  a pre-recorded voice message as contrasted to an ordinary voice message.  29.  Based on the Plaintiff’s own personal experience, the voice messages received  from Defendant clearly sounded as if they were pre-recorded voice messages. 37. Plaintiff reserve the right to modify the Class definitions as warranted as facts are  learned in further investigation and discovery.  38. Plaintiff and the Class members were harmed by Defendant’s acts in at least the  following ways: Defendant, either directly or through its agents, illegally contacted Plaintiffs and  the Class via their cellular telephones by using an ATDS, thereby causing Plaintiffs and the Class  to incur certain cellular telephone charges or reduce cellular telephone time for which Plaintiffs  and the Class members previously paid; and Plaintiffs and Class members' privacy was invaded.  39. The exact size of the Class is presently unknown but can be ascertained through a  review of Defendant’s records, and it is clear that individual joinder is impracticable.  Defendant  made telephone calls to thousands of consumers who fall into the definition of the Classes.  40. There are many questions of law and fact common to the claims of Plaintiffs and  the Classes, and those questions predominate over any questions that may affect individual  members of the Classes.   42. Plaintiff’s claims are typical of the claims of the other members of the Class.   Plaintiff and the Class sustained damages as a result of Defendant’s uniform wrongful conduct  during transactions with Plaintiff and the Class.  43. Plaintiff will fairly and adequately represent and protect the interests of the Class,  and have retained counsel competent and experienced in complex class actions.   44. Plaintiff have no interest antagonistic to those of the Class, and Defendant has no  defenses unique to Plaintiff.  45. This class action is appropriate for class certification because Defendant has acted  or refused to act on grounds generally applicable to the Class as a whole, thereby requiring the  Court’s imposition of uniform relief to ensure compatible standards of conduct toward the Class,  and making final injunctive relief appropriate with respect to the Class as a whole.   46. Defendant’s practices challenged herein apply to and affect the Class members  uniformly, and Plaintiffs’ challenge of those practices hinges on Defendant’s conduct with  respect to the Classes as a whole, not on facts or law applicable only to Plaintiffs.  47. This case is also appropriate for class certification because class proceedings are  superior to all other available methods for the fair and efficient adjudication of this controversy  given that joinder of all parties is impracticable.   48. The damages suffered by the individual members of the Classes will likely be  relatively small, especially given the burden and expense of individual prosecution of the  complex litigation necessitated by Defendant’s actions.   49. Thus, it would be virtually impossible for the individual members of the Classes  to obtain effective relief from Defendant’s misconduct.   51. By contrast, a class action presents far fewer management difficulties and provides the benefits of single adjudication, economy of scale, and comprehensive supervision  by a single court. Economies of time, effort and expense will be fostered, and uniformity of  decisions ensured. 52. Plaintiff re-alleges and incorporates by reference each preceding paragraph as though fully set forth herein.  53. Defendant made unsolicited and unauthorized phone calls using an ATDS to Plaintiff’s and the Class members cellular telephones for the purpose of marketing products  and/or services to Plaintiff and the Class.  54. The foregoing acts and omissions of Defendant constitute numerous and multiple 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.  55. Defendant made unsolicited and unauthorized calls to Plaintiff for the purpose of marketing products and/or services to those Plaintiffs and the Class.  56. Defendant’s conduct invaded Plaintiff’s privacy.  58. Because Defendant had knowledge that Plaintiff never gave her prior express consent, the Court should, pursuant to 47 U.S.C. § 227(b)(3)(C), treble the amount of statutory  damages recoverable by Plaintiffs and the Classes.    59. Plaintiff and the Class are also entitled to and seek injunctive relief prohibiting such conduct in the future. VIOLATIONS OF THE TELEPHONE CONSUMER PROTECTION ACT 47 U.S.C. § 227 