10.  Beginning in or around December 18, 2014, Plaintiff signed up for  two memberships to Defendants’ gym to be charged to Plaintiff’s single debt  account.   11.  On or around February 16, 2016, Plaintiff called Defendants to  cancel both memberships under the debit account and to immediately cease  Defendants’ charging of Plaintiff’s account. In fact, Plaintiff asked Defendants’  representative three times to make sure that both gym memberships would be  canceled, and Defendants’ representative confirmed all three times.   23.  Plaintiff brings this action on behalf of herself and all others  similarly situated, as a member of the proposed class (hereafter “The Class”)  defined as follows:  All persons in the United States whose bank accounts  were debited on a reoccurring basis by Defendants  without Defendants obtaining a written authorization  signed or similarly authenticated for preauthorized  electronic fund transfers within the one year prior to the  filing of this Complaint.   24.  Plaintiff represents, and is a member of, The Class, consisting of all  persons within the United States whose bank account was debited on a recurring  basis by Defendants without Defendants obtaining a written authorization signed  or similarly authenticated for preauthorized electronic fund transfers within the  one year prior to the filing of this Complaint.   25.  Defendants, their employees and agents are excluded from The  Class.  Plaintiffs do not know the number of members in The Class, but believe  the Class members number in the hundreds, if not more.  Thus, this matter should  be certified as a Class Action to assist in the expeditious litigation of the matter.   42.  Plaintiff reincorporates by reference all of the preceding paragraphs.   43.  Section 907(a) of the EFTA, 15 U.S.C. §1693e(a), provides that a  “preauthorized electronic fund transfer from a consumer’s account may be  authorized by the consumer only in writing, and a copy of such authorization  shall be provided to the consumer when made.”   44.  Section 903(9) of the EFTA, 15 U.S.C. § 1693a(9), provides that the  term “preauthorized electronic fund transfer” means “an electronic fund transfer  authorized in advance to recur at substantially regular intervals.”   45.  Section 205.l0(b) of Regulation E, 12 C.F.R. § 205.l0(b), provides  that “[p ]reauthorized electronic fund transfers from a consumer’s account may be  authorized only by a writing signed or similarly authenticated by the consumer.   The person that obtains the authorization shall provide a copy to the consumer.”   46.  Section 205.10(b) of the Federal Reserve Board's Official Staff  Commentary to Regulation E, 12 C.F.R. § 205.l0(b), Supp. I, provides that “[t]he  authorization process should evidence the consumer’s identity and assent to the  authorization.”  Id. at ¶10(b), comment 5.  The Official Staff Commentary further  provides that “[a]n authorization is valid if it is readily identifiable as such and  the terms of the preauthorized transfer are clear and readily understandable.”  Id.  at ¶10(b), comment 6.   DEFENDANTS VIOLATED THE ELECTRONIC FUNDS TRANSFER  ACT  (On Behalf of Plaintiff and the Class)   