10.  Defendant contacted or attempted to contact Plaintiff from telephone  number (925) 359-2273.   11.  Defendant’s calls constituted calls that were not for emergency  purposes as defined by 47 U.S.C. § 227(b)(1)(A).   19.  Plaintiff brings this action individually and on behalf of all others  similarly situated, as a member of the two proposed classes (hereafter, jointly, “The  Classes”).    52.  Pursuant to the Seventh Amendment to the Constitution of the United  States of America, Plaintiff is entitled to, and demands, a trial by jury.  Respectfully Submitted this 21st Day of January, 2020.  8.  Beginning in or around November 2017, Defendant contacted  Plaintiff on Plaintiff’s cellular telephone number ending in -6443, in an attempt to  solicit Plaintiff to purchase Defendant’s services.     9.  Defendant used an “automatic telephone dialing system” as defined  by 47 U.S.C. § 227(a)(1) to place its call to Plaintiff seeking to solicit its services.    Knowing and/or Willful Violations of the Telephone Consumer Protection  Act   47 U.S.C. §227(c)  • As a result of Defendant’s willful and/or knowing violations of 47  U.S.C. §227(c)(5), Plaintiff and the DNC 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(c)(5).   • 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(b)  • As a result of Defendant’s negligent violations of 47 U.S.C.  §227(b)(1), Plaintiff and the ATDS 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).   • 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(c)  • As a result of Defendant’s negligent violations of 47 U.S.C.  §227(c)(5), Plaintiff and the DNC Class members are entitled to and  request $500 in statutory damages, for each and every violation,  pursuant to 47 U.S.C.  227(c)(5).   • Any and all other relief that the Court deems just and proper. 