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Plaintiff Alleges She Suffered ‘Actual Harm’ From Unwanted Club 1 Hotel Calls

Defendant Club 1 Hotels, a travel tech company boasting “the world's largest collection of members-only wholesale hotel rates and direct contracts that are not available to the public,” began “bombarding” plaintiff Lachae Vickers’ cellphone with telemarketing text messages in August…

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2022, to a number listed on the national do not call registry, alleged Vickers’ Telephone Consumer Protection Act class action complaint Monday (docket 1:23-cv-07092) in U.S. District Court for Eastern New York in Brooklyn. “At no point in time” did Vickers, of Queens County, New York, provide Club 1 “with her express written consent to be contacted,” and the company continually ignored her multiple opt-out requests, said the complaint. The defendant’s unsolicited text messages caused Vickers “actual harm,” it said. She estimates she wasted 15-30 seconds reviewing each of the defendant’s unwanted messages, it said. Each time, she had to stop what she was doing “to either retrieve her phone and/or look down at the phone to review the message,” it said. Vickers also wasted 15 minutes “locating and retaining counsel for this case” so she could try to stop the defendant’s unwanted calls, it said.