15.  In or around March 2014, Defendant began placing calls to Plaintiff’s  cellular telephone number, 514-xxx-2718.   16.  Defendant placed the calls to Plaintiff from number 800-355-5443.   17.  When answering Defendant’s calls, Plaintiff heard a prerecorded message  indicating that Defendant was attempting to reach a person other than Plaintiff (the  “Debtor”).  Plaintiff does not know the Debtor.   18.  Defendant obtained Plaintiff’s telephone number by buying it from third  party sources.   19.  At no time did Plaintiff ever provide her cellular phone number to  Defendant.   20.  At no time did Plaintiff ever enter into a business relationship with  Defendant.    21.  At no time did Plaintiff provide Defendant with prior written consent  allowing it to call her cellular phone.    23.  Defendant employs an ATDS which meets the definition set forth in 47  U.S.C. § 227(a)(1), and used its ATDS to make each of the aforementioned calls to  Plaintiff on her cellular phone.   24.  Defendant’s calls to Plaintiff’s cellular telephone were not for “emergency  purposes.”   25.  26.  Plaintiff brings this case as a class action pursuant to Fed. R. Civ. P. 23  on behalf of herself and all others similarly situated.   27.  Plaintiff represents, and is a member of the following class:   All persons within the United States who received any telephone calls  from Defendant or their agent(s) and/or employee(s) to said person’s  cellular telephone made through the use of any automatic telephone  dialing system and/or using an artificial or prerecorded voice within the  four years prior to the filing of this Complaint where the Defendant  obtained the cellular telephone number from a source other than the  called party.   28.  Defendant and its employees or agents are excluded from the Class.   Plaintiff does not know the number of members in the Class, but believes the Class  members number in the several thousands, if not more.  Thus, this matter should be  certified as a class action to assist in the expeditious litigation of this matter.   30.  Upon information and belief, Defendant has placed automated calls to  cellular telephone numbers belonging to thousands of consumers throughout the United  States without their prior express consent.  The members of the Class, therefore, are  believed to be so numerous that joinder of all members is impracticable.   31.  The exact number and identities of the Class members are unknown at  this time and can only be ascertained through discovery.  Identification of the Class  members is a matter capable of ministerial determination from Defendant’s call records.   C. Common Questions of Law and Fact    32.  There are questions of law and fact common to the Class that  predominate over any questions affecting only individual Class members.  These  questions include:  a. Whether Defendant made non-emergency calls to Plaintiff and Class  members’ cellular telephones using an ATDS;  b. Whether Defendant can meet its burden of showing it obtained prior  express consent to make each call;  c. Whether Defendant’s conduct was knowing willful, and/or negligent;  d. Whether Defendant is liable for damages, and the amount of such  damages; and  e. Whether Defendant should be enjoined from such conduct in the  future.   34.  Plaintiff’s claims are typical of the claims of the Class members, as they  are all based on the same factual and legal theories.  E. Protecting the Interests of the Class Members    35.  Plaintiff will fairly and adequately protect the interests of the Class and has  retained counsel experienced in handling class actions and claims involving unlawful  business practices.  Neither Plaintiff nor her counsel has any interests which might  cause them not to vigorously pursue this action.  F. Proceeding Via Class Action is Superior and Advisable    36.  A class action is the superior method for the fair and efficient adjudication  of this controversy.  The interest of Class members in individually controlling the  prosecutions of separate claims against GE is small because it is not economically  feasible for Class members to bring individual actions.   38.  Plaintiff repeats and realleges the above paragraphs of this Complaint and  incorporates them herein by reference.   39.  Defendant negligently placed multiple automated calls to cellular numbers  belonging to Plaintiff and the other members of the Class without their prior express  consent.   40.  Each of the aforementioned calls by Defendant constitutes a negligent  violation of the TCPA.   41.  As a result of Defendant’s negligent violations of the TCPA, Plaintiff and  the Class are entitled to an award of $500.00 in statutory damages for each call in  violation of the TCPA pursuant to 47 U.S.C. § 227(b)(3)(B).   42.  Additionally, Plaintiff and the Class are entitled to and seek injunctive relief  prohibiting such conduct by Defendant in the future.  43.  Plaintiff repeats and realleges the above paragraphs of this Complaint and  incorporates them herein by reference.   44.  Defendant knowingly and/or willfully placed multiple automated calls to  cellular numbers belonging to Plaintiff and the other members of the Class without their  prior express consent.   45.  Each of the aforementioned calls by Defendant constitutes a knowing  and/or willful violation of the TCPA.   47.  Additionally, Plaintiff and the Class are entitled to and seek injunctive relief  prohibiting such conduct by Defendant in the future.  A. The Class   Dated: May �, 2014  JODIE GOWAN,  By    /s/ Sergei Lemberg                  Sergei Lemberg, Esq.  Knowing and/or Willful Violations of the Telephone Consumer Protection Act,  47 U.S.C. § 227, et seq.   Negligent Violations of the Telephone Consumer Protection Act,  47 U.S.C. § 227, et seq.  