10.  In order for Defendant LoanCare to place autodialed and/or prerecorded calls to  consumers, it must have prior express consent before it may place such calls to a consumer.   11.  Yet in violation of this rule, Defendant fails to obtain consent prior to making  autodialed and/or prerecorded collection calls to cellular telephone numbers such as Plaintiff’s  cell phone number, which, on information and belief, it obtained through skip tracing.   16.  In early 2018, Plaintiff began receiving repeated autodialed and/or prerecorded  calls to her cellular phone number from LoanCare primarily using phone number 800-909-9525.    17.  LoanCare has left many prerecorded voicemails for Plaintiff, identifying itself as  being LoanCare, and asking Plaintiff to call 800-909-9525.   18.  Plaintiff has answered calls from LoanCare, but she was unable to speak with a  live agent.    19.  For example, in the beginning of December, 2018, Plaintiff called 800-909-9525.  The automated system asked for Plaintiff’s loan number, which she does not have, and her social  security number. There was no way for her to speak with a live agent using LoanCare’s  automated system since she is not affiliated with LoanCare.   20.  Plaintiff believes she has received dozens of autodialed and/or prerecorded calls  from Defendant.    25.  Plaintiff brings this action pursuant to Federal Rule of Civil Procedure 23(b)(2)  and Rule 23(b)(3) on behalf of herself and all others similarly situated and seeks certification of  the following Class:  Class: All persons in the United States who from four years prior to the filing of  this action through class certification (1) Defendant (or an agent acting on behalf  of Defendant) called, (2) on the person’s cellular telephone, (3) using the same  equipment used to call Plaintiff and/or a prerecorded voice message, and (4) for  whom Defendant claims (a) it obtained prior express written consent in the same  manner as Defendant claims it obtained prior express consent to call Plaintiff, or  (b) Defendant did not obtain prior express consent.   31.  Plaintiff repeats and realleges paragraphs 1 through 30 of this Complaint and  incorporates them by reference herein.   32.  Defendant and/or its agents made unwanted collection telephone calls to cellular  telephone numbers belonging to Plaintiff and the other members of the Class using an autodialer  and/or prerecorded message.    33.  These collection telephone calls were made en masse without the consent of the  Plaintiff and the other members of the Class to receive such collection telephone calls.   34.  Defendant did not have prior express consent from the Plaintiff to call her.    Class Treatment Is Appropriate for Plaintiff’s TCPA Claims    LoanCare Places Autodialed and/or Prerecorded Collection Calls to  Consumers’ Cellular Phone Numbers Without Consent   LoanCare Repeatedly Called Plaintiff’s Cell Phone Number  Using an Autodialer and/or Prerecorded Message Without Plaintiff’s Consent   Telephone Consumer Protection Act  (Violations of 47 U.S.C. § 227)  (On Behalf of Plaintiff and the Class)  