whether any particular class member gave Honda his or her cellphone number “during the transaction that resulted in the debt owed” would require careful review of Honda’s individual records on a member-by-member basis. In other words, Honda argues that the Court would be required to engage in a class-member-specific inquiry to determine whether each recipient consented to receiving calls on their cellphone. This, according to Honda, would result in individualized questions predominating over common questions of law or fact. There is a split of opinion in TCPA cases on whether issues of individualized consent predominate over common questions of law or fact so as to prevent class certification. Compare, e.g., Gene & Gene L.L.C. v. Bio-Pay, L.L.C., 541 F.3d 318, 326-29 (5th Cir. 2008) (<HOLDING>); G.M. Sign, Inc. v. Brink’s Mfg. Co., No. 09 C
holding that the mere existence of individualized factual questions with respect to the class representatives claim will not bar class certification holding that district court abused its discretion in certifying class in light of the individ ual calculation of damages that is required holding that district court abused its discretion in certifying class because the individualized issue of whether fax advertisements were transmitted without the prior express invitation or permission of each recipient prevented plaintiff from advancing any viable theory employing generalized proof concerning the lack of consent with respect to the class  which leads to the conclusion that myriad minitrials cannot be avoided holding that the district court abused its discretion by decertifying the class without permitting class counsel reasonable time to determine whether a new class representative could be substituted holding that the district court did not abuse its discretion in certifying the class but suggesting that prior to trial the district court ensure that appropriate subclasses are identified