12.  All of the Defendants conspired, jointly caused, knowingly participated and/or  aided and abetted each other in the wrongful conduct described hereinafter so as to be jointly and  severally liable to Plaintiff for each of the acts, omissions, breaches, malfeasance and causes of  action set forth herein.    24.  Defendants operate a company that purports to offer credit repair services to its  customers for a fee. Unfortunately for consumers, Defendants utilized (and continued to utilize) a  sophisticated telephone dialing system to call individuals en masse promoting its services.   25.  Defendants obtained these telephone numbers (i.e., leads) by purchasing marketing  lists containing consumers’ telephone numbers and by capturing numbers used to call or submit  web inquiries to Defendants.   26.  Unfortunately, in Defendants’ overzealous attempt to market its services, it placed  (and continue to place) phone calls to consumers who never provided consent to call and to  consumers having no relationship with Defendants. Worse yet, Defendants placed (and continues  to place) repeated and unwanted calls to consumers whose phone numbers are listed on the  National Do Not Call Registry.  Consumers place their phone numbers on the Do Not Call Registry  for the express purpose of avoiding unwanted telemarketing calls like those alleged here.   27.  Defendants knowingly made (and continue to make) these telemarketing calls  without the prior express written consent of the call recipients and knowingly continue to call them  after requests to stop. As such, Defendants not only invaded the personal privacy of Plaintiff and  members of the putative Class, but also intentionally and repeatedly violated the TCPA.  28.  Over six years ago on or about June 11, 2008, Plaintiff registered her cellular phone  number ending in 6312 with the National Do Not Call Registry.  56.  Plaintiff brings this action pursuant to Federal Rule of Civil Procedure 23(a), (b)(2),  and (b)(3) on behalf of herself and the following classes defined as follows (the “Class”):  “Robocall Class”: All individuals in the United States who received a call  made by or on behalf of Defendants to the individual’s cellular telephone  through the use of an automatic telephone dialing system, or pre-recorded  voice, or any other device having the capacity to dial numbers without  human intervention, from October 16, 2013 to the date the Class is certified,  where Defendants’ records fail to indicate prior express written consent  from the recipient to make such call.  76.  Plaintiff re-alleges and incorporates by reference each preceding paragraph as  though set forth at length herein.   77.  Defendants made unsolicited and unauthorized calls using an ATDS or pre- recorded voice to Plaintiff’s and the Class Members’ cellular telephones for the purpose of  marketing products and/or services to Plaintiff and the Plaintiff Class Members.   78.  Defendants made the calls without prior express written consent of the Plaintiff and  Plaintiff Class Members.     79.  The foregoing acts and omissions of Defendants constitute numerous and multiple  violations of the TCPA, including but not limited to each and every one of the above-cited  provisions of 47 U.S.C. § 227, et. seq.  83.  Plaintiff re-alleges and incorporates by reference each preceding paragraph as  though set forth at length herein.   84.  47 U.S.C. § 227(c) provides that 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 the  regulations prescribed under this subsection may” bring a private action based on a violation of  said regulations, which were promulgated to protect telephone subscribers’ privacy rights to avoid  receiving telephone solicitations to which they object.    85.  The TCPA’s implementing regulation—47 C.F.R. § 64.1200(c)—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.” See 47 C.F.R. § 64.1200(c).  A.  CLASS ALLEGATIONS   VIOLATION OF TCPA, 47 U.S.C. § 227  (“DNC Claim” On behalf of Plaintiff and the Class)   VIOLATION OF TCPA, 47 U.S.C. § 227  (“Robocall Claim” On behalf of Plaintiff and the Class)  