 Plaintiff answered the phone and was greeted by a prerecorded or artificial  voice noting that he could be eligible to save money on his home energy bills by getting  solar panels installed on his home and receive government credits to assist with the cost.    After the prerecorded or artificial voice finished, a woman who identified  herself as Leanna came on the line.      After Plaintiff inquired, Leanna indicated that she was calling from “Smart  Home Solar”.  Leanna then asked Plaintiff questions about his energy bills and his home.   She then told Plaintiff that he would likely qualify to have low or no cost solar panels  installed on his home.  After asking additional questions about Plaintiff’s finances and  credit, Leanna then offered to set up an appointment.    Plaintiff recalls having received other calls similar to the June 14, 2018,  Solar Call.    Upon information and belief, Defendants placed other Solar Calls to  Plaintiff during the preceding 12-month period.    Upon information and belief, Defendants used an ATDS, artificial voice, or  a prerecorded voice to place the Solar Calls to Plaintiff and other persons and entities.    In order to investigate who was behind this marketing scheme, Plaintiff  accepted Leanna’s offer, and set up an appointment.    On June 20, 2018, a male person driving a black Toyota Prius wrapped with  an advertisement for vivint.Solar arrived at Plaintiff’s home.  The male person indicated  that his name was Seth Bringhurst and said that he worked for Vivint Solar.  Mr, Bringhurst  was wearing a shirt with the name Vivint on it in orange lettering.  Mr. Bringhurst gave  Plaintiff a business card and a pamphlet that both contained the words “Vivint Solar.”     Plaintiff asked Mr. Bringhurst who “Smart Home Solar” was, as that was  the name of the company that was provided to him during the June 14, 2018, Solar Call.   Mr. Bringhurst responded that Smart Home Solar is a company that generates sales leads,  and that Mr. Bringhurst uses Smart Home Solar for that purpose.    Mr. Bringhurst conducted an inspection, asked Plaintiff questions, and  otherwise touted the products and services of Defendants.    Mr. Bringhurst told Plaintiff that he had been employed by Vivint Solar for  over ten years, and has worked for Vivint Solar in multiple cities.      Mr. Bringhurst provided Plaintiff with his business card that says  vivint.Solar on one side, and included the Vivint Solar website address, and Mr.  Bringhurst’s email address at vivintsolar.com.    Prior to leaving, Mr. Bringhurst asked Plaintiff to sign a form permitting  Defendant Vivint Solar Developer, LLC to obtain Plaintiff’s consumer credit report.    On June 20, 2018, Plaintiff received an email from “Vivint Solar Team”  noting that its sales representative had recently spoken with him, and asking that Plaintiff  confirm his email address.    Pursuant to the TCPA and its implementing regulations, calls placed using  an artificial voice, or a prerecorded voice, that include or introduce an advertisement or  constitute telemarketing may not be placed to persons or entities whose telephone numbers  have been assigned to a cellular telephone service or a residential line without obtaining  Prior Express Written Consent.    Pursuant to the TCPA and its implementing regulations, calls placed using  an ADTS that include or introduce an advertisement or constitute telemarketing may not  be placed to telephone numbers that have been assigned to a cellular telephone service  without obtaining Prior Express Written Consent.    Pursuant to the TCPA and its implementing regulations, 47 C.F.R.    However, Defendants placed the Solar Calls without obtaining the Prior  Express Written Consent of Plaintiff or the other putative class members.    Pursuant to the TCPA and its implementing regulations, telephone  solicitations may not be placed to persons and entities that are registered with the National  Do-Not-Call Registry at least 30 days prior to being called more than once within a 12- month period, and without obtaining prior express invitation or permission evidenced by a  signed, written agreement between the consumer and seller which states that the consumer  agrees to be contacted by this seller and includes the telephone number to which the calls  may be placed.    However, Defendants placed the Solar Calls despite the fact that Plaintiff’s  and other putative class members’ phone numbers were on the National Do-Not-Call  Registry, and without obtaining the Requisite Do-Not-Call Permission of Plaintiff or the  other putative class members.    Plaintiff brings this action as a class action, pursuant to Rule 23(a) and  23(b)(3), Federal Rules of Civil Procedure, for statutory damages on behalf of himself and  a class of all persons similarly situated.    Class Size (Fed. R. Civ. P. 23(a)(1)): Plaintiff avers that the proposed class  is in excess of 50 persons. The class size is so numerous that joinder of all members is  impracticable.      Fair and Adequate Representation (Fed. R. Civ. P. 23(a)(4)): The named  Plaintiff will fairly and adequately represent and protect the interests of the class members.   Plaintiff is committed to this cause, will litigate it vigorously, and is aware of the fiduciary  duties of a class representative.  Plaintiff’s interests are consistent with and not antagonistic  to the interests of the other class members.  Plaintiff has a strong personal interest in the  outcome of this action and has retained experienced class counsel to represent his and the  other class members.    Class Counsel is experienced in class action litigation and has successfully  litigated class claims.    Plaintiff reasserts and incorporates herein by reference the averments set  forth in paragraphs 1 through 40, above.    Plaintiff brings this action against the Defendants for sending Solar Calls to  himself and to members of the Plaintiff Class in violation of the TCPA and its  implementing regulations.    Defendants violated the TCPA and implementing regulations 47 C.F.R. §    Defendants violated the TCPA and implementing regulation 47 C.F.R. §    The named Plaintiff and members of the Plaintiff Class are entitled to  $1,500 for each violation of each of the Solar Calls that violated 47 C.F.R. § 64.1200(a)  and $1,500 for each of the Solar Calls that violated 47 C.F.R. § 64.1200(c) that was placed  to them willfully or knowingly.   200(c), by initiating or authorizing the placement of the Solar Calls to the phone  numbers of Plaintiff and the members of the Plaintiff Class where such persons and entities  were registered with the National Do-Not-Call Registry at least 30 days prior to being  called by Defendants more than once within a 12-month period, and without obtaining  Requisite Do-Not-Call Permission from Plaintiff or members of the Plaintiff Class.   200(a), by initiating or authorizing the placement of the Solar Calls to the phone  numbers of Plaintiff and the members of the Plaintiff Class without receiving Prior Express  Written Consent.    On June 14, 2018, Defendants placed the June 14, 2018, Solar Call to  Plaintiff’s cell phone, while he was in the District of Columbia.  The call came from a  number with a 202 area code.   