17.  Unfortunately for consumers, Defendant utilized (and continues to utilize) a  sophisticated telephone dialing system to send text messages to individuals en masse promoting  its services. On information and belief, Defendant obtained these telephone numbers (i.e., leads)  by purchasing marketing lists containing consumers’ telephone numbers.   27.  Plaintiff restates, re-alleges and incorporates by reference each preceding  paragraph as though fully set forth herein.   28.  Defendant sent unsolicited and unauthorized text messages using an ATDS to  Plaintiff’s and the Class members’ cellular telephones for the purpose of marketing products  and/or services to Plaintiff and the Class.   29.  Plaintiff sent the text messages without obtaining prior express written consent  from Plaintiff and the Class.   30.  The foregoing acts and omissions of Defendant 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.   31.  Defendant’s conduct invaded Plaintiff’s privacy.   32.  As a result of Defendant’s violations of 47 U.S.C. § 227, et seq., Plaintiff and the  Class are entitled to an award of $500.00 in statutory damages, for each and every violation,  pursuant to 47 U.S.C. § 227(b)(3)(B).   33.  Because Defendant had knowledge that Plaintiff and the Class did not consent to  the receipt of the aforementioned telephone solicitations, and Defendant knowingly and  intentionally made the telephone solicitations to Plaintiff, the Court should, pursuant to 47 U.S.C.  § 227(b)(3)(C), treble the amount of statutory damages recoverable by Plaintiff and the Class.   34.  Plaintiff and the class are also entitled to and seek injunctive relief prohibiting  such conduct in the future.   51.  Plaintiff restates, re-alleges and incorporates by reference paragraphs 1 through  27 as though fully set forth herein.   52.  On or about December 27, 2019, Plaintiff received a text messages (“Text”) on  her cellular telephone stating “The Care Team at MultiCare Health System values your feedback.   Please take a short survey.  https://pgsms.co/h6v6x3y3hf3n5k5g.”  A true and correct copy of the  screen shot of the Text is attached hereto as Exhibit A.   53.  Plaintiff is informed and believes, upon such information and belief avers, that  Defendant sent text messages to consumers en masse.   54.  The texts are advertisements of Defendant’s services containing automated  content.   COUNT I  VIOLATONS OF THE TELEPHONE CONSUMER PROTECTION ACT  47 U.S.C. § 227 FOR THE USE OF AN ATDS    UNSOLICITED TEXT MESSAGES  