 Plaintiff pays for and maintains a cellular telephone number ending in 3436.    Beginning in January 2013, Defendants began placing calls to Plaintiff's cellular  telephone number, sometimes multiple times per day.    During at least some of these calls, Defendants left a voice message for Plaintiff  using artificial or prerecorded voice.    Other than Defendants' calls, Plaintiff has had no contact with Defendants.      Plaintiff never solicited Defendants' calls and never otherwise gave Defendants  express permission to call.    Plaintiff has tried repeatedly to make Defendants stop these incessant calls.    On four separate occasions in 2013 - February 28, March 1, March 4, and March  5 - Plaintiff called Defendants to request that the calls stop.    On each occasion, Defendants assured Plaintiff that her number would no longer  be called.    Defendants have called Plaintiff at least thirty-six (36) times since she last  requested that Defendants cease calling her.    Defendants' calls for Plaintiff were placed from Defendants' automatic telephone  dialing system, as defined by 47 U.S.C. § 227(a)(1), from the phone number that is registered to  Defendants.       Specifically, Defendants' dialing system has the capacity to store, dial, and  generate phone numbers such as Plaintiff's.     Defendants' calls were made to Plaintiff's cellular phone and she was charged for  those phone calls.    Plaintiff never provided express consent for Defendants to place calls to her  cellular phone with Defendants' automatic telephone dialing system or to call her using an using  an artificial or prerecorded voice.     Defendants' conduct has caused Plaintiff to incur actual damages including but  not limited to cellular phone charges, anxiety, sleeplessness, and worry and she was forced to  tend to unwanted calls.   Plaintiff incorporates all previous paragraphs of this Complaint.    It is a violation of the TCPA, 47 U.S.C. § 227(b)(1)(A)(iii), to call a person's  cellular telephone using an automatic telephone dialing system.      Defendants called plaintiff and others on their cellular telephones using an  automatic telephone dialing system.    Defendants called plaintiff and others on their cellular telephones using an using  an artificial or prerecorded voice.    Plaintiff and the class are entitled to have their rights, status and legal relations  under the TCPA relating to defendant's calling of cell phones using an automatic dialing system.    The Defendants’ calls were negligent, or alternatively, as evidenced by  Defendants’ refusal to comply with Plaintiff’s requests to cease calling, they were willful.  47  U.S.C. §312(f)(1).   Class Allegations    Plaintiff brings Count I on behalf of a class, which consists of:  All persons nationwide who AHB, Homeland or some person on their behalf called on  their cell phone using a device that has the capacity to dial numbers without human  intervention, where the recipient of the call did not give either defendant the phone  number for purposes such calls, where any call was made on or after a date four years  before the filing of this complaint.     The class is sufficiently numerous to make joinder impracticable. The only use for  automatic dialing equipment is to make a high volume of telephone calls in a short period of  time.     Common questions of law and fact exist as to all members of the class and  predominate over any questions solely affecting any individual member of the class, including  plaintiff. Such questions common to the Class include, but are not limited to:   a.  Whether defendants used an automatic telephone dialing system as that  term us defined in the TCPA and applicable FCC regulations and orders; and  b.  Damages, including whether the violation was willful.     Class action treatment is superior to the alternatives for the fair and efficient  adjudication of the controversy alleged herein. Such treatment will permit a large number of  similarly situated persons to prosecute their common claims in a single forum simultaneously,  efficiently, and without the duplication of effort and expense that numerous individual actions  would entail.     No difficulties are likely to be encountered in the management of this class action  that would preclude its maintenance as a class action, and no superior alternative exists for the  fair and efficient adjudication of this controversy.      Defendants have acted on grounds generally applicable to the class, thereby  making relief appropriate with respect to the class as a whole.  Prosecution of separate actions by  individual members of the class, should they realize their rights have been violated, would likely  create the risk of inconsistent or varying adjudications with respect to individual members of the  class that would establish incompatible standards of conduct.     The identity of the class is likely readily identifiable from defendant's records.    Plaintiff incorporates all previous paragraphs of this complaint.    It is a violation of 47 C.F.R. § 64.1200(d) to have insufficient procedures in place  to ensure requests that calls cease are honored.    It is a violation of the TCPA, 47 C.F.R. § 64.1200(d)(3) to call a residential or  cellular telephone for telemarketing purposes, if the consumer has requested that calls cease.     A private right of action attaches when more than two such calls are made within  a twelve month period. 47 U.S.C. § 227(c)(5).    Defendants called Plaintiff and others more than once within a 12 month period  on her residential and cellular telephone for telemarketing purposes, without having sufficient  procedures in place to avoid calling persons who previously requested that calls cease. 47 C.F.R.  § 64.1200(d).     Alternatively, Defendants had no procedures at all.     Plaintiff brings Count II on behalf of a class, which consists of:  All persons nationwide who AHB, Homeland or some person on their behalf called on  their residential or cell phone for the purpose of selling goods or services, where  defendants had in place the same or similar company specific do not call policy, practice  or procedure (or lack thereof) as when plaintiff was called, where the phone number was  called more than twice in a 12 month period.   Plaintiff alleges a subclass of persons who were called more than twice after they  had requested that calls cease.     The class is sufficiently numerous to make joinder impracticable. The only use for  automatic dialing equipment is to make a high volume of telephone calls in a short period of  time.     Common questions of law and fact exist as to all members of the class and  predominate over any questions solely affecting any individual member of the class, including  plaintiff. Such questions common to the Class include, but are not limited to:   c.  Whether Defendants’ company specific do not call policies, practices and  procedures complied with the TCPA, including 47 C.F.R. § 64.1200(d); and  d.  Damages, including whether the violation was willful.     Plaintiff will fairly and adequately protect the interests of the class.  Plaintiff has  no interests that might conflict with the interests of the class. Plaintiff is interested in pursuing  his claims vigorously, and has retained counsel competent and experienced in class and complex  litigation.      No difficulties are likely to be encountered in the management of this class action  that would preclude its maintenance as a class action, and no superior alternative exists for the  fair and efficient adjudication of this controversy.      Defendants have acted on grounds generally applicable to the class, thereby  making relief appropriate with respect to the class as a whole.  Prosecution of separate actions by  individual members of the class, should they realize their rights have been violated, would likely  create the risk of inconsistent or varying adjudications with respect to individual members of the  class that would establish incompatible standards of conduct.     The identity of the class is likely readily identifiable from Defendant's records.  