10.  Defendant used an “automatic telephone dialing system” as defined  by 47 U.S.C. § 227(a)(1) to place its call to Plaintiff seeking to solicit its services.    11.  On or about February 17, 2020, Defendant contacted or attempted to  contact Plaintiff from telephone number (480) 926-4000 confirmed to be  Defendant’s number. When Plaintiff answered the call, there was a pre-recorded  voice on the other line.    12.  Defendant’s calls constituted calls that were not for emergency  purposes as defined by 47 U.S.C. § 227(b)(1)(A).   13.  Defendant’s calls were placed to telephone number assigned to a  cellular telephone service for which Plaintiff incurs a charge for incoming calls  pursuant to 47 U.S.C. § 227(b)(1).    18.  Plaintiff brings this action individually and on behalf of all others  similarly situated, as a member the two proposed classes (hereafter, jointly, “The  Classes”).    19.  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   8.  Defendant contacted Plaintiff on Plaintiff’s cellular telephone  number ending in -6678, in an attempt to solicit Plaintiff to purchase Defendant’s  services numerous times within the last 12 months.     9.  The calls at issue solicited Plaintiff’s business in the form of  requesting that he bring his vehicle into Defendant’s place of business for the  purpose of purchasing repair and maintenance services.     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), Plaintiff and the ATDS 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).   • Any and all other relief that the Court deems just and proper.  