Floyd

I. BACKGROUND

1 A. Factual Background 2 Plaintiff Floyd is a resident of Campbell, California. Comp. at ¶ 1. Defendant Saratoga is 3 a California corporation with its principal place of business in Saratoga, California. Id. at ¶ 2. 4 Defendant Pallone is the President of Saratoga. Id. at ¶ 27. 5 On March 12, 2019, Defendants transmitted a facsimile advertisement by fax to Plaintiff. 6 Id. at ¶ 18. This fax advertised continuing medical education seminars. Id. Plaintiff did not 7 provide permission or invite Defendants to send a fax to Plaintiff and Plaintiff has no prior 8 relationship with Defendants. Id. at ¶ 23. 9 Plaintiff alleges on information and belief that Defendants faxed the same unsolicited 10 facsimile to more than 40 other recipients without those recipients’ permission or invitation. Id. at 11 ¶ 24. 12 B. Procedural History 13 Plaintiff filed a complaint in the instant action on March 1, 2020. ECF No. 1. Plaintiff’s 14 complaint alleges a single cause of action for violation of the Telephone Consumer Protection Act 15 (“TCPA”), as amended by the Junk Fax Prevention Act (“JFPA”), 47 U.S.C. § 227, et seq. Id. at ¶ 16 42. 17 Plaintiff served Pallone by…