 Upon the opening of the account, Plaintiff was registered for Online Banking by  providing his cellphone number as instructed by SunTrust.    Shortly thereafter, Plaintiff began receiving text messages from SunTrust on his  cellular phone.      The Plaintiff’s cellular phone number is identified as 757-###-6812.      Based upon information and belief, the Defendant sent the text messages using an  automatic dialing system as defined by 47 U.S.C. § 227(a)(1).     On or about December 2, 2019, the Plaintiff texted “STOP” from his cell phone to  “shortcode” 786411 as instructed by the SunTrust Online Services Agreement that governed his  banking relationship with SunTrust.       Plaintiff thereafter continued to receive text messages from the Defendant.    On December 13, 2019, Plaintiff sent a letter to Truist requesting that it stop  sending text messages to his cell phone.     This letter was received by the Defendant.    The Plaintiff thereafter continued to receive text messages from the Defendant.     On or about December 17, 2019, the Plaintiff sent a second letter to Truist via its  registered agent in Raleigh, North Carolina, requesting that it stop sending text messages to his  cell phone.    This letter was received by the Defendant.    The Plaintiff thereafter continued to receive text messages from the Defendant.    The Plaintiff continued to receive text messages from the Defendant.    On or about March 26, 2020, the Plaintiff sent a fourth letter by registered mail  addressed to Truist Bank via its registered agent in Glen Allen, Virginia requesting that it stop  sending text messages to his cell phone.    The Plaintiff continued to receive text messages from the Defendant.    Despite the Defendant receiving multiple notifications from the Plaintiff that he did  not want to receive text messages from Truist, the Defendant continued to send text messages to  the Plaintiff’s cellular phone.     The Defendant failed to comply with the requirements of the TCPA and associated  governing F.C.C. Rules and Regulations by continuing to transmit unwanted text messages via an  ATDS to the Plaintiff after he had revoked his consent, causing the Plaintiff to sustain damages to  include, but not limited to: intrusion on the Plaintiff’s privacy, occupation of the capacity of the  Plaintiff’s cell phone, loss of the Plaintiff’s time, additional cellular charges, and accompanying  emotional distress.    The Defendant is aware of its obligations under the TCPA.    Despite knowing these legal obligations, the Defendant acted consciously in  breaching its known duties and violated the Plaintiff’s rights by failing to cease sending text  messages to Plaintiff’s cell phone using an ATDS after the Plaintiff revoked his consent.      The Defendant’s conduct was not a mere mistake or accident.  Instead, it was the  intended result of its standard operating procedures, and the Defendant’s violations were  willfully and knowingly committed.     The Plaintiff restates each of the allegations in paragraphs 1 through 33 as if set  forth at length herein.    Pursuant to Rule 23 of the Federal Rules of Civil Procedure, the Plaintiff brings this  action for himself and on behalf of a class defined as follows:  All natural persons residing in the United States (a) who opened a Truist checking  account, (b) within the four-year period preceding the filing of this action and  during its pendency, (c) to whom Truist thereafter sent text messages using an  ATDS, (d) after such date as the class member revoked his or her consent. Excluded  from the class definition are any employees, officers, or directors of Truist, any  attorney appearing in this case, and any judge assigned to hear this action.     The Plaintiff also bring this action on behalf of a portion of the Class described as  the following subclass:  The Short Code Subclass  All natural persons residing in the United States (a) who opened a SunTrust/Truist  checking account, (b) within the four-year period preceding the filing of this action  and during its pendency, and (c) to whom Truist thereafter sent text messages using  an ATDS, (d) after such date as the class member revoked his or her consent by  sending the word “STOP” or any sentence, word, phrase or string of letters  containing the word “STOP” to short code 786411. Excluded from the class  definition are any employees, officers, or directors of Truist, any attorney appearing  in this case, and any judge assigned to hear this action.     The Plaintiff’s claim is typical of those of the class members.  All are based on the  same facts and legal theories.  Truist’s failure to stop sending text messages using an ATDS after  a person revokes consent is typical of its regular business practices and policies.      The Plaintiff will fairly and adequately protect the interests of the class.  The  Plaintiff has retained counsel experienced in handling class actions.  Neither the Plaintiff nor his  counsel has any interests that might cause them to not vigorously pursue this action. The Plaintiff  is aware of his responsibilities to the putative class and has accepted such responsibilities.    Certification of a class under Rule 23(b)(1) of the Federal Rules of Civil Procedure  is proper.  Prosecuting separate actions would create a risk of adjudications that would be  dispositive of the interests of the other members not parties to the individual adjudications or would  substantially impair their ability to protect their interests.      Certification of a class under Rule 23(b)(2) of the Federal Rules of Civil Procedure  is appropriate in that the Defendant has acted on grounds generally applicable to the class, thereby  making appropriate declaratory relief with respect to the class as a whole.    Truist violated 47 U.S.C. § 227(b)(1)(A)(iii) by using an ATDS to send text  messages to the Plaintiff and purported class members’ phones lines after they revoked their  consent.     The Defendant’s conduct was not a mere mistake or accident. Instead, it was the  intended result of their standard operating procedures    As a result of Truist’s conduct and actions, the Plaintiff and purported class  members suffered actual damages.     As a result of Truist’s conduct and actions, the Plaintiff and purported class  members are entitled to statutory damages.    Defendant’s violations of 47 U.S.C. § 227(b)(1)(A)(iii) were willfully and  knowingly committed, rendering the Defendant liable for actual or statutory damages, and treble  damages under 47 U.S.C. § 227(b)(3).  Violation of 47 U.S.C. § 227(b)(1)(A)(iii)  