(Violations of the Telephone Consumer Protection Act, 47 U.S.C. § 227(b)(1))  On Behalf of Plaintiff and the Class   18. Enacted in 1991, the TCPA makes it unlawful “to make any call (other than a call  made for emergency purposes or made with the prior express consent of the called party) using  an automatic telephone dialing system or an artificial or prerecorded voice . . . to any telephone  number assigned to a . . . cellular telephone service.”  47 U.S.C. § 227(b)(1).   19. Calls made by an ATDS or with a prerecorded or artificial voice are referred to as  “robocalls” by the Federal Communications Commission (“FCC”) and herein.   20. Encouraging people to hold robocallers accountable on behalf on their fellow  Americans, the TCPA provides a private cause of action to persons who receive such calls.  47  U.S.C. § 227(b)(3).   96. Plaintiff realleges and incorporates by reference each and every allegation set forth in  the preceding paragraphs.   97. Defendant violated the TCPA, 47 U.S.C. § 227(b)(1), by placing non-emergency calls  to the cellular telephone numbers of Plaintiff and members of the class using an ATDS and/or  artificial or prerecorded voice.   98. Plaintiff and class members are entitled to an award of up to $1,500 in damages for  each knowing or willful violation and of $500 for each other violation.  47 U.S.C.  § 227(b)(3)(B).   99. Plaintiff and class members are entitled to and seek an injunction prohibiting  Defendant and all other persons who are in active concert or participation with it from violating  the TCPA, 47 U.S.C. § 227(b)(1), by placing non-emergency calls to any cellular telephone  number using an ATDS and/or artificial or prerecorded voice.  A.  The Enactment of the TCPA and the FCC’s Regulations Thereunder  