10.  Defendants contacted Plaintiff via facsimile from telephone numbers  confirmed to belong to Defendants.   11.  Defendants contacted Plaintiff on or around April 2018 in an effort to  solicit its business.   12.  Defendants’ messages constituted “telephone solicitation” as defined  by the TCPA, 47 U.S.C. § 227(a)(4) and “unsolicited advertisement” as defined by  the TCPA, 47 U.S.C. § 227(a)(5).   13.  Defendants used an “telephone facsimile machine” as defined by 47  U.S.C. § 227(a)(3) to place its calls to Plaintiff seeking to sell or solicit its business  services.   17.  Plaintiff brings this action on behalf of himself and all others similarly  situated, as a member of the proposed class (hereafter “The Class”) defined as  follows:  All persons within the United States who received any  telephone facsimile messages from Defendants to said  person’s telephone facsimile number made through the  use of any telephone facsimile machine and such person  had not previously consented to receiving such messages    18.  Plaintiff represents, and is a member of, The Class, consisting of All  persons within the United States who received any telephone facsimile messages  from Defendants to said person’s telephone facsimile number made through the use  of any telephone facsimile machine and such person had not previously provided  their telephone facsimile number to Defendants within the four years prior to the  filing of this Complaint.   9.  Beginning in or around April of 2018, Defendants contacted Plaintiff  on his telephone facsimile numbers ending in -3052, in an effort to sell or solicit its  services.    Knowing and/or Willful Violations of the Telephone Consumer Protection Act   47 U.S.C. §227 et seq.  • As a result of Defendants’ willful and/or knowing violations of 47  U.S.C. §227(b)(1), Plaintiff and the 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); and   • 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 et seq.  • As a result of Defendants’ negligent violations of 47 U.S.C.  §227(b)(1), Plaintiff and the Class 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); and  • Any and all other relief that the Court deems just and proper.  