62.  Plaintiff re-alleges and incorporates the foregoing allegations as if fully set  forth herein.    63.  It is a violation of the TCPA to make “any call (other than a call made for  emergency purposes or made with the prior express consent of the called party) using  any automatic telephone dialing system … to any telephone number assigned to a …  cellular telephone service ….” 47 U.S.C. § 227(b)(1)(A)(iii).    64.  Defendant – or third parties directed by Defendant – used equipment  having the capacity to dial numbers without human intervention to make non- emergency telephone calls to the cellular telephones of Plaintiff and the other members  of the Class defined below.    65.  These calls were made without regard to whether or not Defendant had  first obtained express permission from the called party to make such calls. In fact,  Defendant did not have prior express consent to call the cell phones of Plaintiff and  the other members of the putative Class when its calls were made.    69.  Plaintiff re-alleges and incorporates the foregoing allegations as if fully set  forth herein.   70.  At all times relevant, Defendant knew or should have known that its  conduct as alleged herein violated the TCPA.   71.  Defendant knew that it did not have prior express consent to make these  calls, and knew or should have known that its conduct was a violation of the TCPA.   72.  Because Defendant knew or should have known that Plaintiff and Class  Members had not given prior express consent to receive its autodialed calls, the Court  should treble the amount of statutory damages available to Plaintiff and the other  members of the putative Class pursuant to § 227(b)(3) of the TCPA.   73.  As a result of Defendant’s violations, Plaintiff and the Class Members 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)(B) and 47 U.S.C. § 227(b)(3)(C).  Knowing and/or Willful Violation of the TCPA, 47 U.S.C. § 227(b)  (On Behalf of Plaintiff and the Class)   PROPOSED CLASS   Violations of the TCPA, 47 U.S.C. § 227(b)  (On Behalf of Plaintiff and the Class)  