10. Plaintiff alleges that at all times relevant herein Defendant conducted  business in the State of California, County of San Diego, and within this  judicial district.   11. Sometime prior to December of 2016, Plaintiff allegedly incurred debts to  Defendant for an account ending in 9942 and an account ending in 4396.   12. Beginning around June of 2017, Defendant initiated multiple telephonic  communications to Plaintiff’s cellular telephone ending in “9532”.  Plaintiff  found these communications excessive, inconvenient and harassing.   28. Plaintiff brings this action on behalf of herself and on behalf of all others  similarly situated (“the Class”).   29. Plaintiff represents, and is a member of the Class, consisting of:  All persons within the United States who received any  text messages from Defendant or their agent/s and/or  employee/s, not sent for emergency purposes, to said  person’s cellular telephone made through the use of any  automatic telephone dialing system within the four years  prior to the filing of this Complaint.   30. Defendant and its employees or agents are excluded from the Class.   Plaintiff does not know the number of members in the Class, but believes the  Class members number in the hundreds of thousands, if not more.  Thus, this  matter should be certified as a Class action to assist in the expeditious  litigation of this matter.   41. Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   42. The foregoing acts and omissions of Defendant constitutes 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.   43. As a result of Defendant’s 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).   44. Plaintiff and the Class are also entitled to and seek injunctive relief  prohibiting such conduct in the future.  45. Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   46. The foregoing acts and omissions of Defendant constitutes 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.   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.   THE TCPA, 47 U.S.C. § 227 ET SEQ.  • As a result of Defendant’s 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).  • Pursuant to 47 U.S.C. § 227(b)(3)(A), injunctive relief prohibiting such  conduct in the future.  • Any other relief the Court may deem just and proper. 