64.1200(c)(2) provides that “[n]o person or entity shall initiate any telephone solicitation” to a  “residential telephone subscriber who has registered his or her telephone number on the national  do-not-call registry of persons who do not wish to receive telephone solicitations that is  maintained by the Federal Government.” 47 C.F.R. § 64.1200(e) extends the privacy protection  in subsection 64.1200(c) to wireless telephone numbers.   64.1200(d); Liberty Power consistently fail to honor the requests of Plaintiff and other  individuals to stop calling, and specifically to place their name and telephone number on Liberty  Power’s internal do not call list and to otherwise maintain an adequate do not call policy required  under 47 C.F.R. § 64.1200(d).   70.  Plaintiff hereby incorporates by reference the allegations contained in all  preceding paragraphs of this complaint. Plaintiff asserts this claim on behalf of himself and the  members of the Artificial/Prerecorded Voice Class.   71.  The TCPA prohibits certain uses of telecommunication equipment that would  interfere with telephone service subscribers’ privacy and/or property rights with respect to their  telephone. In particular, the TPCA makes it unlawful for any person:  to initiate any telephone call to any residential telephone line using an  artificial or prerecorded voice to deliver a message without the prior  express consent of the called party, unless the call is initiated for  emergency purposes or is exempted by rule or order by the Commission  under paragraph (2)(B).   47 U.S.C. § 227(b)(1)(B).    73.  Liberty Power and its agents also utilized artificial and/or prerecorded voice  messages in calls to residential telephones of Plaintiff and Artificial/Prerecorded Voice Class  members.   74.  Liberty Power and its agents do not and did not obtain legally effective prior  express consent to call the Artificial/Prerecorded Voice Class members’ residential telephone  numbers.    75.  Liberty Power and its agents violated 47 U.S.C. § 227(b)(1)(A)(iii) by placing  telephone calls to the residential telephone numbers of Plaintiff and the other members of the  Artificial/Prerecorded Voice Class using an artificial or prerecorded voice without their prior  express written consent.    76.  Liberty Power willfully violated 47 U.S.C. § 227(b)(1)(A)(iii) because it knew  that Plaintiff and the other Artificial/Prerecorded Voice Class members had not given prior  express consent to receive calls made using an artificial, and/or prerecorded voice and that  Liberty Power and its agents used these methods to call the residential telephone numbers of  Plaintiff and the other Artificial/Prerecorded Voice Class members.    77.  Plaintiff, individually, and on behalf of the other members of the  Artificial/Prerecorded Voice Class, seeks to recover statutory damages (including treble damages  for willful violations), as well as injunctive and equitable relief under 47 U.S.C. § 227(b)(3)  against Liberty Power.   78.  Plaintiff hereby incorporates by reference the allegations contained in all  preceding paragraphs of this complaint. Plaintiff asserts this claim on behalf of himself and  members of the National DNC Class.   80.  Liberty Power and its agents violated 47 C.F.R. § 64.1200(c) by initiating  telephone solicitations to wireless and residential telephone subscribers such as Plaintiff and the  other National DNC Class members.    81.  Liberty Power did not have an established business relationship with Plaintiff and  class members.    82.  Liberty Power and its agents made more than one unsolicited telephone call to  Plaintiff and members of the class within a 12-month period without their prior express consent  to receive such calls. Plaintiff and members of the National DNC Class never provided any form  of consent to receive telephone calls from Liberty Power and/or Liberty Power does not have any  legally effective evidence of consent to place telemarketing calls to them.   83.  Plaintiff and the other members of the National DNC Class have a claim against  Liberty Power because Plaintiff and the other members of the National DNC Class received  more than one telephone call within a 12-month period made by or on behalf of the Liberty  Power in violation of 47 C.F.R. § 64.1200. As a result of the conduct of Liberty Power and its  agents, Plaintiff and the class suffered actual damages and have a claim for $500 in statutory  damages for each such violation of 47 C.F.R. § 64.1200, and injunctive relief. 47 U.S.C. §  227(c)(5).   85.  Plaintiff, individually, and on behalf of the other members of the National DNC  Class, seeks to recover statutory damages (including treble damages for willful violations), as  well as injunctive and equitable relief under 47 U.S.C. § 227(c)(5) against Liberty Power.   86.  Plaintiff hereby incorporates by reference the allegations contained in all  preceding paragraphs of this complaint. Plaintiff asserts these claims on behalf of himself and  members of the Internal DNC Class.   88.  The TCPA creates a private right of action for injunctive and monetary relief for  any “person who has received more than one telephone call within any 12–month period by or on  behalf of the same entity in violation of [e.g., 47 C.F.R. § 64.1200(d).]” 47 U.S.C. § 227(c)(5).  See also 47 C.F.R. § 64.1200(d)(3) (liability for company specific DNC list violations).   89.  Liberty Power did not institute minimum procedures required under 47 C.F.R. §   90.  Liberty Power and its agents violated 47 C.F.R. § 64.1200(d) by initiating calls  for telemarketing purposes to residential and wireless telephones of Plaintiff and members of the  class without instituting minimum procedures required under 47 C.F.R. § 64.1200(d).    91.  Liberty Power willfully violated 47 C.F.R. § 64.1200(d).  Liberty Power knew  that it and its agents failed to institute minimum procedures for maintaining a list of persons who  request not to receive telemarketing calls made by or on behalf of Liberty Power and that they  repeatedly ignored and/or refused to honor Plaintiff and class members’ requests to be placed on  a company DNC list.     Violations of the TCPA Against Corp and Holding   by Plaintiff, Individually and on Behalf of the National DNC Class    Violation of the TCPA Against Corp and Holding   by Plaintiff, Individually, and on Behalf of the Artificial/Prerecorded Voice Class     Violations of the TCPA, 47 U.S.C. § 227  Against Corp and Holding   by Plaintiff Individually and on Behalf of the Internal DNC Class  