 Requiring SCS to hire a Court-approved, independent auditing  company to (a) investigate all allegations of TCPA violations, and  (b) audit no less than 10% of SCS’s outbound calls to ensure that  SCS had consent and that the consumer had not previously asked  that calls stop, and (c) report the results of the above investigations  to the Court and Plaintiff’s counsel on a quarterly basis.  D.   Damages pursuant to 47 U.S.C. § 227(b)(3)(B), for each and every  nonconsensual call to each and every class member;  E.  Treble damages pursuant to 47 U.S.C. § 227(b)(3), as to each  violation;  F.  Attorneys’ fees and costs, as permitted by law; and  G.  Such other or further relief as the Court deems just and proper.  8   In response to Defendant’s phone calls, Plaintiff consulted with the attorneys at  Community Lawyers Group, Ltd., who, on July 19, 2017 sent a letter to SCS demanding that it  cease communication with Plaintiff and direct all calls to Plaintiff’s attorney.    SCS received Plaintiff’s letter on July 19, 2017.    Yet SCS continued calling Plaintiff, and on August 22, 2017, left a pre-recorded  voice message on Defendant’s cellular telephone, without her permission.    During Defendant’s calls, pre-recorded voice messages were left asking Plaintiff  to press a number depending on her identity, which is the result of a dialer calling and no  operator or representative of Defendant being immediately available to speak.    Therefore SCS used software which has the capacity to predictively dial in its  telephone calls to Defendant.     SCS’s business model is to knowingly use an auto-dialer to call cellular  telephones it knows it does not have consent to call, and to hide behind an arbitration clause  when challenged in court.    Many of the numbers SCS calls to collect a debt are obtained by “skip-tracing,”  an investigative method used to obtain consumer phone numbers from online databases and  credit reports, rather than from consumers themselves.    As a result, many of these numbers are called without express consent of the  consumer, who did not provide the number in the first place.    Many of the numbers SCS calls are obtained when consumers seek medical  services, even though those consumers do not give their consent to be called by SCS’ autodialer.  4    Upon information and belief, SCS already keeps records and data from which it  can determine which autodialed calls it made without consent, but has elected not to engage such  to prevent TCPA violations for business reasons.    Defendant knew about the TCPA before making the calls to plaintiff and the  class, but made these autodialed calls to cellular phones in spite of such knowledge.     Defendant also knew that they did not have “prior express consent” to call phone  numbers that had been obtained through skip trace or any means other than directly from the  called party, or that any such consent had been revoked.    On information and belief, SCS has used an Aspect Software, Inc. brand  autodialer for some of the calls.     On information and belief, SCS also used third party vendors to make calls,  including Livevox and others.     Documents in SCS’s possession will show that she never gave her consent to  receive calls to her cellular telephone.    Those documents will also confirm that Plaintiff notified SCS to stop calling her  cellular telephone.     SCS’s records will show that it logged Plaintiff’s withdrawal of any apparent  consent in its computer.    The telephone calls were annoying to Plaintiff, invaded Plaintiff’s privacy  interests, and temporarily blocked use of her cellular telephone line for other potential callers.    The telephone calls were intentionally, willfully and knowingly initiated.     The telephone calls were not initiated by accident or mistake.   Plaintiff brings this action on behalf of a class consisting of:  All persons in the United States whose cellular telephone number, on or  after four years prior to the filing of this action, SCS called using the same  or similar dialing system used to call Plaintiff, where such calling occurred  without the person’s permission.    Plaintiff additionally brings this action on behalf of a subclass consisting of:  All persons in the United States whose cellular telephone number, on or  after four years prior to the filing of this action, SCS called using the same  or similar dialing system used to call Plaintiff, where the person or their  representative revoked any prior consents to be called.    Upon information and belief, in the four years prior to the filing of this action,  there were more than 100 persons whose cell phone number SCS called without permission  using the same equipment used to call Plaintiff.    Common questions of law or fact exist as to all members of the class, which  predominate over any questions solely affecting any individual member, including Plaintiff.  Such questions common to the class include but are not limited to:  a. Whether the calls to Plaintiff and the class were made using an “automatic  telephone dialing system” as such term is defined or understood under the TCPA  and applicable FCC regulations and orders;  b. Whether the calls to Plaintiff and the class were made using a prerecorded  message as such term is defined or understood under the TCPA and applicable  FCC regulations and orders;  c. Whether SCS had prior express consent to the cell phone numbers of Plaintiff and  the other members of the class; and  6  d. Damages, including whether any violations were performed willfully or  knowingly such that Plaintiff and the other members of the class are entitled to  treble damages under 47 U.S.C. § 227(b)(3).    Plaintiff’s claims are typical of the claims of the other members of the class. The  factual and legal bases of SCS’s liability to Plaintiff and the other members of the class are the  same: SCS violated the TCPA by causing automated calls to be made to the cellular telephone  number of each member of the class, without permission.    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  her claims vigorously, and she has retained counsel competent and experienced in class and  complex litigation.    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 action  would entail. There are, on information and belief, thousands of class members, such that joinder  of all members is impracticable.    No difficulties are likely to be encountered in the management of this action that  would preclude its maintenance as a class action, and no superior alternative exists for the fair  and efficient adjudication of this controversy.    Defendant has acted and failed to act on grounds generally applicable to Plaintiff  and the other members of 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 even  7  realize that 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, on information and belief, readily identifiable from  Defendant’s records.  WHEREFORE, Plaintiff Kathleen Taylor, individually and on behalf of the class,  respectfully requests that the Court enter judgment against Defendant for:  A.  Certification of the class and subclass as alleged herein;  B.   A declaration that SCS violated the TCPA as to Plaintiff and each class;  C.   Injunctive relief aimed at ensuring the prevention of SCS from violating  the TCPA in the future, including:   5    Plaintiff has received multiple calls to her cellular telephone from Defendant.  Most of these calls are believed to have happened in March through August 2017, although there  very well may have been calls before and after that period.    Calls made to Plaintiff were unanswered but left pre-recorded voice messages  directed to Plaintiff.  3  