 Plaintiff Abante is the owner and customary user of a cellphone number ending in  5154.     At no time did Abante provide its cellphone number to Defendant or provide  Defendant, or any of Defendant’s agents, with prior express consent to call.     At all times relevant hereto, and for a period of at least thirty (30) days prior to the  relevant period of time, Plaintiff’s cellphone number was and remains registered on the DNC  Registry.     Plaintiff brings this action in accordance with Federal Rule of Civil Procedure  23(b)(2) and Rule 23(b)(3) on behalf of himself and two Classes defined as follows:  Autodialed Class: All persons in the United States who (1) from the date four years  prior to the filing of this Complaint through the date notice is sent to the Class; (2)  Defendant caused to be called; (3) on the person’s cellphone; (4) for the same  purpose as Defendant called Plaintiff; (5) using the same equipment that was used  to call the Plaintiff, and (6) for whom Defendant claims it obtained prior express  consent in the same manner as Defendant claims it obtained prior express consent  to call the Plaintiff.  Stop Class: All persons in the United States (1) who were called by Defendant; (2)  who requested that Defendant not call them again; and (3) who, despite asking not  to be called, received at least one additional call from Defendant using the same  equipment that was used to call the Plaintiff.    Plaintiff incorporates the foregoing allegations as if fully set forth herein.    Defendant made or caused to be made calls to Plaintiff’s and the other Autodialed  Class Members’ cellphones.     These calls were made using equipment that had the capacity to store or produce  telephone numbers using a random or sequential number generator, to receive and store lists of  phone numbers, and to dial such numbers, en masse, without human intervention. The telephone  dialing equipment utilized by Defendant, also known as a predictive dialer, dialed numbers from a  list, or dialed numbers from a database of telephone numbers, in an automatic and systematic  manner. Defendant’s autodialer disseminated information en masse to Plaintiff and other  consumers and is an ATDS under the TCPA.    The calls were for telemarketing purposes, specifically to apprise Plaintiff and  others of the availability of Harbortouch’s credit/debit card processing services.    Neither Plaintiff nor any other consumer ever provided prior express consent under  the TCPA to be called by or on behalf of Harbortouch.     As a result of Defendant’s unlawful conduct, Plaintiff and the other members of  the Autodialed Class suffered actual damages and, under section 47 U.S.C. § 227(c)(5), Plaintiff  and each member of the Autodialed Class are each entitled to receive up to $500 in damages for  each violation of 47 C.F.R. § 64.1200.     Should the Court determine that Defendant’s conduct was willful and knowing, the  Court may, pursuant to Section 227(c)(5), treble the amount of statutory damages recoverable by  Plaintiff and the other members of the Autodialed Class.    Plaintiff incorporates the foregoing allegations as if fully set forth herein.    Plaintiff and other members of the Stop Class expressly requested that Defendant  no longer place calls to them.    Rather than honor these requests or place Plaintiff and the members of the Stop  Class on its internal do not call list, if any, Defendant Harbortouch continued to call Plaintiff and  others who asked not to be called.     No consent was ever provided, and any consent that was ever hypothetically  provided had been revoked. Despite this, Harbortouch continued to make calls, or to cause calls to  be made, to Plaintiff and other members of the Stop Class.     The calls were made using equipment that had the capacity to store or produce  telephone numbers using a random or sequential number generator, to receive and store lists of  phone numbers, and to dial such numbers, en masse, without human intervention. The telephone  dialing equipment utilized by Defendant, also known as a predictive dialer, dialed numbers from a  list, or dialed numbers from a database of telephone numbers, in an automatic and systematic  manner. Defendant’s autodialer disseminated information en masse to Plaintiff and other  consumers and is an ATDS under the TCPA.    As a result of Defendant’s unlawful conduct, Plaintiff and the Stop Class suffered  actual damages and, under section 47 U.S.C. § 227(c)(5), Plaintiff and each member of the Stop  Class are entitled to receive up to $500 in damages for each violation of 47 C.F.R. § 64.1200.    In the event the Court determines that Defendant’s conduct was willful and  knowing, the Court may, pursuant to Section 227(c)(5), treble the amount of statutory damages  recoverable by Plaintiff and the other members of the DNC Stop Class.    Defendant Harbortouch is a merchant processing company that contracts with  businesses to provide credit card and debit card processing services, including point of sale card  readers and related equipment.    Violation of 47 U.S.C. § 227, et seq.  (On behalf of Plaintiff and the Autodialed Class)   Violation of 47 U.S.C. § 227, et seq.  (On behalf of Plaintiff and the Stop Class)  