Complaint — Doe v. AcmeMortgage Inc.

complaint · v1 · status draft · ROSENTHAL matter · prior review time 0 min

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# COMPLAINT FOR VIOLATION OF THE TELEPHONE CONSUMER PROTECTION ACT

Plaintiff JANE DOE, by and through undersigned counsel, alleges as follows against Defendant ACMEMORTGAGE INC.:

## I. JURISDICTION AND VENUE

1. This Court has subject matter jurisdiction under 28 U.S.C. § 1331 because this action arises under the Telephone Consumer Protection Act, 47 U.S.C. § 227 ("TCPA").

2. Venue is proper in this District under 28 U.S.C. § 1391(b)(2).

## II. PARTIES

3. Plaintiff is a natural person residing in Los Angeles County, California.

4. Defendant is a Delaware corporation with its principal place of business in Irvine, California.

## III. FACTUAL ALLEGATIONS

5. Beginning on or about January 15, 2026, Defendant placed at least thirty-seven (37) calls to Plaintiff's cellular telephone number using an automatic telephone dialing system, in violation of 47 U.S.C. § 227(b)(1)(A)(iii).

6. Plaintiff never provided prior express consent to receive such calls. *See Van Patten v. Vertical Fitness Group, LLC*, 847 F.3d 1037, 1044 (9th Cir. 2017) (express consent must be specific to the type of call).

7. After Plaintiff revoked any arguable consent on February 3, 2026, Defendant continued to place calls in violation of *Marks v. Crunch San Diego, LLC*, 904 F.3d 1041 (9th Cir. 2018).

## IV. CLAIM FOR RELIEF

8. Plaintiff seeks statutory damages of $500 per violation under 47 U.S.C. § 227(b)(3)(B), trebled to $1,500 per violation for knowing or willful violations.

9. Plaintiff also seeks an injunction under 47 C.F.R. § 64.1200(c).

WHEREFORE, Plaintiff prays for judgment against Defendant.

Respectfully submitted,
[Founder name TODO], Esq.
California Bar No. [TBD]

Citations (3)

unverifiedstatute· federal
unverifiedstatute· federal
unverifiedcase· 9th Cir.

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