Case 5:20-cv-00980-JGB-KK Document 1 Filed 05/06/20 Page 1 of 13 Page ID #:1
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`Seth M. Lehrman (178303)
`seth@epllc.com
`EDWARDS POTTINGER LLC
`425 North Andrews Avenue, Suite 2
`Fort Lauderdale, FL 33301
`Telephone: 954-524-2820
`Facsimile: 954-524-2822
`
`Attorney for Plaintiff
`Vanessa Camacho
`
`
`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF CALIFORNIA
`EASTERN DIVISION
`CASE NO.
`VANESSA CAMACHO, individually and )
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`on behalf of all others similarly situated,
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`CLASS ACTION COMPLAINT
`Plaintiff,
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`v.
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`JURY TRIAL DEMANDED
`HYDROPONICS, INC.,
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`Defendant.
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`Plaintiff, Vanessa Camacho (hereinafter “Plaintiff”), brings this class action
`under Rule 23 of the Federal Rules of Civil Procedure against Hydroponics, Inc.
`(“Hydroponics” or “Defendant”) for its violations of the Telephone Consumer
`Protection Act, 47 U.S.C. § 227 (hereinafter “the TCPA”), and the regulations
`promulgated thereunder. In support, Plaintiff alleges as follows:
`PRELIMINARY STATEMENT
`1.
`Plaintiff brings this Class Action Complaint for damages, injunctive relief,
`and any other available legal or equitable remedies, resulting from the illegal actions
`of Defendant in negligently or willfully contacting Plaintiff on Plaintiff’s cellular
`telephone, in violation of the Telephone Consumer Protection Act, 47 U.S.C. § 227
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`(“TCPA”), thereby invading Plaintiff’s privacy. Plaintiff alleges as follows upon
`personal knowledge as to herself and her own acts and experiences, and, as to all
`other matters, upon information and belief, including investigation conducted by her
`attorneys.
`2.
`“Month after month, unwanted robocalls and texts, both telemarketing and
`informational, top the list of consumer complaints received by the [FCC].”1 The
`TCPA is designed to protect consumer privacy by, among other things, prohibiting
`the making of autodialed or prerecorded-voice calls to cell phone numbers and
`failing to institute appropriate do-not-call procedures. 47 U.S.C. § 227(b)(1)(A)(iii);
`47 C.F.R. § 64.1200(d).
`3.
`The TCPA was designed to prevent calls like the ones described within
`this complaint, and to protect the privacy of citizens like Plaintiff. “Voluminous
`consumer complaints about abuses of telephone technology – for example,
`computerized calls dispatched to private homes – prompted Congress to pass the
`TCPA.” Mims v. Arrow Fin. Servs., LLC, 132 S. Ct. 740, 744 (2012).
`4. Additionally, the FCC has explicitly stated that the TCPA’s prohibition on
`automatic telephone dialing systems “encompasses both voice calls and text calls to
`wireless numbers including, for example, short message service (SMS) calls.”
`U.S.C.A. Const. Amend. 5; Telephone Consumer Protection Act of 1991, § 3(a), 47
`U.S.C. § 227(b)(1)(A)(iii). Kramer v. Autobytel, Inc., 759 F. Supp. 2d 1165 (N.D.
`Cal. 2010).
`5.
`In enacting the TCPA, Congress intended to give consumers a choice as to
`how creditors and telemarketers may call them and made specific findings that
`“[t]echnologies that might allow consumers to avoid receiving such calls are not
`universally available, are costly, are unlikely to be enforced, or place an inordinate
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`In re Rules & Regs. Implementing the TCPA, 30 FCC Rcd. 7961, ¶ 1 (2015).
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`burden on the consumer. TCPA, Pub.L. No. 102–243, § 11. Toward this end,
`Congress found that:
`[b]anning such automated or prerecorded telephone calls to the home,
`except when the receiving party consents to receiving the call or when
`such calls are necessary in an emergency situation affecting the health
`and safety of the consumer, is the only effective means of protecting
`telephone consumers from this nuisance and privacy invasion.
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`Id. at § 12; see also Martin v. Leading Edge Recovery Solutions, LLC, 2012
`WL 3292838, at *4 (N.D. Ill. Aug. 10, 2012) (citing Congressional findings on
`TCPA’s purpose).
`6.
`In an action under the TCPA, a plaintiff must only show that the defendant
`“called a number assigned to a cellular telephone service using an automatic dialing
`system or prerecorded voice.” Breslow v. Wells Fargo Bank, N.A., 857 F. Supp. 2d
`1316, 1319 (S.D. Fla. 2012), aff'd, 755 F.3d 1265 (11th Cir. 2014).
`JURISDICTION AND VENUE
`7. This Court has federal question subject matter jurisdiction pursuant to 28
`U.S.C. § 1331 and 47 U.S.C. § 227.
`8. Venue in this judicial district is proper under 28 U.S.C. § 1391(b)(2),
`because a substantial part of the events or omissions giving rise to the claims in this
`case occurred in this District, including Defendant’s transmission of the unlawful
`and unwanted calls to Plaintiff.
`9. The Court has personal jurisdiction over Defendant because it conducts
`business in this state, markets its services within this state, and has availed itself to
`the jurisdiction of this state by placing calls to Plaintiff and Class Members in and
`from this state.
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`PARTIES
`10. Plaintiff’s domicile is in Riverside, California.
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`11. Defendant is a California Profit Corporation and citizen of the state of
`California, listing its principal address at 17 Corporate Plaza, Newport Beach, CA
`92660. Hydroponics is also registered in the state of California.
`12. Defendant promotes and markets its services by calling wireless telephone
`users in violation of the TPCA.
`13. Defendant, directly or through other persons, entities or agents acting on
`its behalf, conspired to, agreed to, contributed to, authorized, assisted with, and/or
`otherwise caused all of the wrongful acts and omissions, including the dissemination
`of the unsolicited calls that are the subject matter of this Complaint.
`FACTUAL ALLEGATIONS
`14. At all times relevant, Plaintiff, and at all times mentioned herein was, a
`“person” as defined by 47 U.S.C. § 153 (39).
`15. Defendant is a citizen of the State of California, and at all times mentioned
`herein was, a corporation and “persons,” as defined by 47 U.S.C. § 153(39).
`16. At all times relevant Defendant conducted business in the State of
`California in Orange County, within this judicial district.
`17. Defendant utilizes automated telemarketing text messages to market and
`advertise Defendant’s business and services, including at least three (3) messages to
`Plaintiff, from September 18, 2019 to October 29, 2019, attached below:
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`18. The text messages were transmitted to Plaintiff’s 3760 Number, and within
`the time period that is relevant to this action.
`19. At no time did Plaintiff provide Plaintiff’s cellular number to Defendant
`through any medium, nor did Plaintiff consent to receive such unsolicited text
`messages.
`20. Plaintiff has never signed-up for, and has never used, Defendant’s services,
`and has never had any form of business relationship with Defendant.
`21. Plaintiff is the subscriber and sole user of the 3760 Number and is
`financially responsible for phone service to the 3760 Number, including the cellular
`costs and data usage incurred as a result of the unlawful text messages made to
`Plaintiff by Defendant.
`22. Through the unsolicited messages, Defendant contacted Plaintiff on
`Plaintiff’s cellular telephone regarding an unsolicited service via an “automatic
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`telephone dialing system” (“ATDS”), as defined by 47 U.S.C. § 227(a)(1) and
`prohibited by 47 U.S.C. § 227(b)(1)(A).
`23. Upon information and belief, this ATDS has the capacity to store or
`produce telephone numbers to be called, using a random or sequential number
`generator.
`24. Upon information and belief, this ATDS has the capacity to store numbers
`and to dial numbers without human intervention.
`25. Upon information and belief, Defendant used a combination of hardware
`and software systems which have the capacity to generate or store random or
`sequential numbers or to dial sequentially or randomly in an automated fashion
`without human intervention.
`26. The impersonal and generic nature of the text messages that Defendant
`sent to Plaintiff further demonstrates that Defendant used an ATDS to send the
`subject messages.
`27. The content of the text messages made to Plaintiff and the Class Members
`show that they were for the purpose of marketing, advertising, and promoting
`Defendant’s business and services to Plaintiff as part of an overall telemarketing
`strategy.
`28. These messages were not for emergency purposes as defined by 47 U.S.C.
`§ 227(b)(1)(A)(i).
`29. Plaintiff did not provide Defendant or its agents prior express consent to
`receive messages to her cellular telephone; therefore, the unsolicited messages
`violated 47 U.S.C. § 227(b)(1)
`30. Defendant is and was aware that it is transmitting unsolicited telemarketing
`text messages to Plaintiff and other consumers without their prior express consent.
`31. Plaintiff was damaged by Defendant’s messages. In addition to using
`Plaintiff’s residential cellular data, phone storage, and battery life, her privacy was
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`wrongfully invaded, her seclusion was intruded upon, and Plaintiff has become
`understandably aggravated with having to deal with the frustration of repeated,
`unwanted messages, forcing her to divert attention away from her work and other
`activities. Not only did the receipt of the text messages distract Plaintiff away from
`her personal activities, Plaintiff was forced to spend time investigating the source of
`the calls and who sent them to her. See Muransky v. Godiva Chocolatier, Inc., 905
`F.3d 1200, 1211 (11th Cir. 2018). (“[T]ime wasting is an injury in fact”…. “[A]
`small injury… is enough for standing purposes”).
`CLASS ACTION ALLEGATIONS
`32. Plaintiff brings this class action under Rule 23(a),(b)(2), and(b)(3) of the
`Federal Rules of Civil Procedure on behalf of herself and of a similarly situated
`“Class” or “Class Members” defined as:
`No Consent Class: All persons within the United States who, within
`the four years prior to the filing of this Complaint, were sent a text
`message by Defendant or anyone on Defendant’ behalf, to said person’s
`cellular telephone number, advertising Defendant’s services, without
`the recipients prior express consent, using the same equipment used to
`call Plaintiff’s cellular telephone, in violation of the TCPA.
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`33. Excluded from the Class are Defendant, and any subsidiary or affiliate of
`Defendant, and the directors, officers and employees of Defendant or its subsidiaries
`or affiliates, and members of the federal judiciary.
`34. This action has been brought and may properly be maintained as a class
`action against Defendant pursuant to Rule 23 of the Federal Rules of Civil Procedure
`because there is a well-defined community of interest in the litigation and the
`proposed Class is easily ascertainable. Plaintiff reserves the right to amend the Class
`definition if discovery and further investigation reveal that any Class should be
`expanded or otherwise modified.
`35. Numerosity: At this time, Plaintiff does not know the exact number of
`Class Members, but among other things, given the nature of the claims and that
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`Defendant’s conduct consisted of standardized SPAM campaign calls placed to
`cellular telephone numbers, Plaintiff believes, at a minimum, there are greater than
`forty (40) Class Members. Plaintiff believes that the Class is so numerous that
`joinder of all members of the Class is impracticable and the disposition of their
`claims in a class action rather than incremental individual actions will benefit the
`Parties and the Court by eliminating the possibility of inconsistent or varying
`adjudications of individual actions.
`36. Upon information and belief, a more precise Class size and the identities
`of the individual members thereof are ascertainable through Defendant’s records,
`including, but not limited to Defendant’s calls and marketing records.
`37. Members of the Class may additionally or alternatively be notified of the
`pendency of this action by techniques and forms commonly used in class actions,
`such as by published notice, e-mail notice, website notice, fax notice, first class mail,
`or combinations thereof, or by other methods suitable to this class and deemed
`necessary and/or appropriate by the Court.
`38. Existence and Predominance of Common Questions of Fact and Law:
`There is a well-defined community of common questions of fact and law affecting
`the Plaintiff and members of the Class. Common questions of law and/or fact exist
`as to all members of the Class and predominate over the questions affecting
`individual Class members. These common legal and/or factual questions include,
`but are not limited to, the following:
`a. Whether, within the four years prior to the filing of this Complaint,
`Defendant or its agents called (other than a message made for
`emergency purposes or made with the prior express consent of the
`called party) to a Class member using any automatic dialing to any
`telephone number assigned to a cellular phone service;
`b. How Defendant obtained the numbers of Plaintiff and Class members;
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`c. Whether the dialing system used to call is an Automatic Telephone
`Dialing System;
`d. Whether Defendant engaged in telemarketing when it sent the text
`messages which are the subject of this lawsuit;
`e. Whether the calls made to Plaintiff and Class Members violate the
`TCPA and its regulations;
`f. Whether Defendant willfully or knowingly violated the TCPA or the
`rules prescribed under it;
`g. Whether Plaintiff and the members of the Class are entitled to statutory
`damages, treble damages, and attorney fees and costs for Defendant’s
`acts and conduct;
`h. Whether Plaintiff and members of the Class are entitled to a permanent
`injunction enjoining Defendant from continuing to engage in its
`unlawful conduct; and
`i. Whether Plaintiff and the Class are entitled to any other relief.
`39. One or more questions or issues of law and/or fact regarding Defendant’s
`liability are common to all Class Members and predominate over any individual
`issues that may exist and may serve as a basis for class certification under Rule
`23(c)(4).
`40. Typicality: Plaintiff’s claims are typical of the claims of the members of
`the Class. The claims of the Plaintiff and members of the Class are based on the
`same legal theories and arise from the same course of conduct that violates the
`TCPA.
`41. Plaintiff and members of the Class each received at least one telephone
`call, advertising the Defendant’s hydroponics products or services, which Defendant
`placed or caused to be placed to Plaintiff and the members of the Class.
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`42. Adequacy of Representation: Plaintiff is an adequate representative of
`the Class because Plaintiff’s interests do not conflict with the interests of the
`members of the Class. Plaintiff will fairly, adequately and vigorously represent and
`protect the interests of the members of the Class and has no interests antagonistic to
`the members of the Class. Plaintiff has retained counsel competent and experienced
`in litigation in the federal courts, TCPA litigation, and class action litigation.
`43. Superiority: A class action is superior to other available means for the fair
`and efficient adjudication of the claims of the Class. While the aggregate damages
`which may be awarded to the members of the Class are likely to be substantial, the
`damages suffered by individual members of the Class are relatively small. As a
`result, the expense and burden of individual litigation makes it economically
`infeasible and procedurally impracticable for each member of the Class to
`individually seek redress for the wrongs done to them. Plaintiff does not know of
`any other litigation concerning this controversy already commenced against
`Defendant by any member of the Class. The likelihood of the individual members
`of the Class prosecuting separate claims is remote. Individualized litigation would
`also present the potential for varying, inconsistent or contradictory judgments, and
`would increase the delay and expense to all parties and the court system resulting
`from multiple trials of the same factual issues. In contrast, the conduct of this matter
`as a class action presents fewer management difficulties, conserves the resources of
`the parties and the court system, and would protect the rights of each member of the
`Class. Plaintiff knows of no difficulty to be encountered in the management of this
`action that would preclude its maintenance as a class action.
`44. Class-Wide Injunctive Relief and Rule 23(b)(2): Moreover, as an
`alternative to or in addition to certification of the Class under Rule 23(b)(3), class
`certification is warranted under Rule 23(b)(2) because Defendant has acted on
`grounds generally applicable to Plaintiff and members of Class, thereby making
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`appropriate final injunctive relief with respect to Plaintiff and Class Members as a
`whole. Plaintiff seeks injunctive relief on behalf of Class Members on grounds
`generally applicable to the entire Class in order to enjoin and prevent Defendant
`Defendant’s ongoing violations of the TCPA, and to order Defendant to provide
`notice to them of their rights under the TCPA to statutory damages and to be free
`from unwanted calls.
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`COUNT I
`VIOLATIONS OF THE TELEPHONE CONSUMER PROTECTION ACT
`47 U.S.C. § 227(b)
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`45. Plaintiff incorporates by reference all of the allegations contained in all of
`the above paragraphs 1 through 44 of this Complaint as though fully stated herein.
`46. It is a violation of the TCPA to make “any call (other than a call made for
`emergency purposes or made with the prior express consent of the called party) using
`any automatic telephone dialing system. . .to any telephone number assigned to a . .
`. cellular telephone service . . .” 47 U.S.C. § 227(b)(1)(A)(iii).
`47. Automatic telephone dialing system refers to “equipment which has the
`capacity---(A) to store or produce telephone numbers to be called, using a random
`or sequential number generator; and (B) to dial such numbers.” 47 U.S.C. §
`227(a)(1).
`48. Defendant—or third parties directed by Defendant—used equipment
`having the capacity to randomly or sequentially generate telephone numbers and to
`dial such numbers without human intervention to make non-emergency telephone
`calls to the cellular telephones of Plaintiff and the other members of the Class
`defined above.
`49. These calls were made without regard to whether or not Defendant had
`first obtained express permission from the called party to make such calls. In fact,
`Defendant did not have prior express consent to call the cellular phones of Plaintiff
`and the other members of the putative Class when its calls were made.
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`50. Defendant has, therefore, violated Section 227(b)(1)(A)(iii) of the TCPA
`by using an automatic telephone dialing system to make non-emergency telephone
`calls to the cellular phones of Plaintiff and the other members of the putative Class
`without their prior express written consent.
`51. The foregoing acts and omissions of Defendant constitute numerous and
`multiple violations of the TCPA, including but not limited to each and every one of
`the above-cited provisions of 47 U.S.C. § 227.
`52. As a result of Defendant’s negligent violations of 47 U.S.C. § 227, Plaintiff
`and the Class are entitled to an award of $500.00 in statutory damages, for each and
`every violation, pursuant to 47 U.S.C. § 227(b)(3)(B).
`53. At all relevant times, Defendant knew or should have known that its
`conduct as alleged herein violated the TCPA.
`54. Defendant knew that it did not have prior express consent to make these
`calls and knew or should have known that its conduct violated the TCPA.
`55. Because Defendant knew or should have known that Plaintiff and Class
`Members did not give prior express consent to receive autodialed calls, the Court
`should treble the amount of statutory damages available to Plaintiff and members of
`the Putative Class pursuant to Section 227(b)(3)(C).
`56. As a result of Defendant knowing and/or willful violations of 47 U.S.C. §
`227(b), Plaintiff and the Class are entitled to an award of $1,500.00 in statutory
`damages, for each and every violation, pursuant to 47 U.S.C. § 227(b)(3)(C).
`57. Plaintiff and the Class are also entitled to and seek injunctive relief
`prohibiting such conduct in the future.
`WHEREFORE, Plaintiff respectfully requests the Court grant Plaintiff and the
`Class members relief against Defendant, as set forth in the Prayer for Relief below.
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`PRAYER FOR RELIEF
`WHEREFORE, Plaintiff requests that the Court enter judgment in her favor
`and in favor of the class, against Defendant for:
`a. An order certifying this case as a class action, certifying Plaintiff as
`representative of the Class, and designating Plaintiff’s counsel as Class
`counsel;
`b. Statutory damages of $500 per call in violation of the TCPA;
`c. Willful damages at $1,500 per call in violation of the TCPA;
`d. A declaration that Defendant’s practices described herein violate the
`Telephone Consumer Protection Act, 47 U.S.C. § 227(b)(1)(A)(iii);
`e. An injunction prohibiting Defendant from using an automatic telephone
`dialing system to call numbers assigned to cellular telephones without
`the prior express written consent of the called party;
`f. Reasonable attorney’s fees and costs; and
`g. Such further and other relief as this Court deems reasonable and just.
`DEMAND FOR JURY TRIAL
`Plaintiff demands a trial by jury.
`
`EDWARDS POTTINGER LLC
`
`
`By: /s/ Seth M. Lehrman
`
`Seth M. Lehrman
`Attorney for Plaintiff
`Vanessa Camacho
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`DATED: May 6, 2020
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