16.  Defendants sell extended auto warranty contracts.    17.  To increase their sales and avoid paying for legitimate forms of advertising, Defendants  repeatedly called and sent prerecorded voice messages to thousands or possibly tens of thousands of cell  phones at once.     18.  When the Class members answered their cell phones or listened to their messages expecting  to hear from a real person, Defendants pulled a bait and switch by playing a prerecorded voice message.     19.  Unfortunately, Defendants failed to obtain consent from Plaintiff and the Class before  bombarding their cell phones with these illegal voice recordings.  20.  On October 23, 2020, Plaintiff received a call from Defendants and/or their agents on his  cell phone number ending in 1146.   21.  When Plaintiff listened to the message, he heard an artificial or prerecorded voice message  advertising Defendants’ auto warranties.    22.  The artificial or prerecorded message said “Hi, Jeep owner this is Jessica, calling in regards  to your warranty renewal on your Jeep. Call me back at 888-217-4270.  You now qualify for a $1000  instant rebate and free maintenance plan.”   23.  Plaintiff called Defendants back and was solicited for a vehicle service contract from Car  Guard and Mepco.   25.  Plaintiff’s phone number had been registered on the Do Not Call Registry since December  17, 2004.     26.  Plaintiff never consented to receive calls from Defendants.  Plaintiff had no relationship  with Defendants and has never requested that Defendants contact him in any manner.    27.  Defendants’ calls violated Plaintiff’s statutory rights and his right to privacy.   28.  Class Definition: Plaintiff brings this action pursuant to Federal Rule of Civil Procedure  23(b)(3) on behalf of himself and a class defined as follows:  No Consent Class.  All persons in the United States who: (1) from the last 4  years to present (2) received at least one telephone call; (3) on his or her cellular  telephone; (4) that was played an artificial or prerecorded voice message; (5)  for the purpose of selling Defendants’ products and/or services;   29.  The following people are excluded from the Class: (1) any Judge or Magistrate presiding  over this action and members of their families; (2) Defendants, Defendants’ subsidiaries, parents,  successors, predecessors, and any entity in which the Defendants or their parents have a controlling  interest and its current or former employees, officers and directors; (3) persons who properly execute and  file a timely request for exclusion from the Class; (4) persons whose claims in this matter have been  finally adjudicated on the merits or otherwise released; (5) Plaintiff’s counsel and Defendants’ counsel;  and (6) the legal representatives, successors, and assigns of any such excluded persons.   30.  Numerosity: The exact number of the Class members is unknown and not available to  Plaintiff, but it is clear that individual joinder is impracticable. On information and belief, Defendants  placed telephone calls to thousands of consumers who fall into the definition of the Class. Members of  the Class can be identified through Defendants’ records.   31.  Typicality: Plaintiff’s claims are typical of the claims of other members of the Class, in  that Plaintiff and the Class members sustained damages arising out of Defendants’ uniform wrongful  conduct and unsolicited telephone calls.   33.  Policies Generally Applicable to the Class: This class action is appropriate for  certification because Defendants have acted or refused to act on grounds generally applicable to the Class  as a whole, thereby requiring the Court’s imposition of uniform relief to ensure compatible standards of  conduct toward the Class members and making final injunctive relief appropriate with respect to the Class  as a whole. Defendants’ practices challenged herein apply to and affect the Class members uniformly,  and Plaintiff’s challenge of those practices hinge on Defendants’ conduct with respect to the Class as a  whole, not on facts or law applicable only to Plaintiff.   34.  Commonality and Predominance: There are many questions of law and fact common to  the claims of Plaintiff and the Class, and those questions predominate over any questions that may affect  individual members of the Class. Common questions for the Class include, but are not necessarily limited  to the following:  i.  Whether Defendants’ conduct violated the TCPA;  ii.  Whether Defendants called and played its voice recordings to thousands of cellular and  residential phones;  iii.  Whether Defendants obtained prior written consent prior to contacting any members of the  Class;  iv.  Whether members of the Class are entitled to treble damages based on the knowingness or  willfulness of Defendants’ conduct.   36.  Plaintiff incorporates the foregoing allegations as if fully set forth herein.   37.  Defendants and/or its agent placed telephone calls to Plaintiff’s and the Class members’  cellular telephones without having their prior express written consent to do so.   38.  Defendants’ calls were made for a commercial purpose.   39.  Defendants played an artificial or prerecorded voice message to the cellular and residential  phones of Plaintiff and the Class members as proscribed by 47 U.S.C. § 227(b)(1)(A)(iii) and (B)   40.  As a result of its unlawful conduct, Defendants repeatedly invaded Plaintiff’s and the  Class’s personal privacy, causing them to suffer damages and, under 47 U.S.C. § 227(b)(3)(B), entitling  them to recover $500 in civil fines for each violation and an injunction requiring Defendants to stop their  illegal calling campaign.   41.  Defendants and/or its agent made the violating calls “willfully” and/or “knowingly” under  47 U.S.C. § 227(b)(3)(C).   42.  If the court finds that Defendants willfully and/or knowingly violated this subsection, the  court may increase the civil fine from $500 to $1500 per violation under 47 U.S.C. § 227(b)(3)(C).  Violation of 47 U.S.C. § 227  (On behalf of Plaintiff and the Class)  