LE GRANDE v. VICTORIA’S SECRET STORES, LLC,

• Site function, like menu drop-down options; not labeled to integrate with the screen reader;
• Empty links;
• Links not labeled, and;
• Content is presented with a loss of information.
• The Website also lacks prompting information and accommodations necessary to allow visually disabled individuals who use screen reader software to locate and accurately fill-out online forms to purchase Defendant’s merchandise from the Website.

Americans with Disabilities Act, 42 U.S.C. § 12181 et seq. 

• A declaration that Defendant’s Website is in violation of the ADA;
• An Order requiring Defendant, by a date certain, to remove barriers and come into full compliance with the requirements of the ADA by curing the defects set forth herein in order that individuals with visual disabilities can access, and continue to
  access, the Website and effectively communicate with the Website to the full extent required by Title III of the ADA;
• An Order requiring Defendant, by a date certain, to clearly display the universal disabled logo within the Website, wherein the logo (see Fn. 1) would lead to a page which would set forth Defendant’s accessibility information, facts, policies, and
  accommodations. Such a clear display of the disabled logo is to ensure that individuals who are disabled are aware of the availability of the accessible features of the Website;
• An Order directing Defendant, by a date certain, to make publicly available and directly link from the Website homepage, a statement of Defendant’s Accessibility Policy to ensure the persons with disabilities have full and equal enjoyment of the Website and shall accompany the public policy statement with an accessible means of submitting accessibility questions and problems.
• An Order requiring Defendant, by a date certain, to provide ongoing support for web accessibility by implementing a website accessibility coordinator, a website application accessibility policy, and provide for website accessibility feedback to ensure compliance thereto.
• An Order directing Defendant, by a date certain, to evaluate its
  policies, practices and procedures toward persons with disabilities, for such reasonable time to allow Defendant to undertake and complete corrective procedures to the Website;
• An Order directing Defendant, by a date certain, to establish a policy of web accessibility and accessibility features for the Website to ensure effective communication for individuals who are visually disabled;
• An Order requiring, by a date certain, that any third-party vendors who participate on Defendant’s Website be fully accessible to the visually disabled;
• An Order directing Defendant, by a date certain and at least once every three months thereafter, to conduct automated accessibility tests of the Website to identify any instances where the Website is no longer in conformity with the accessibility requirements of the ADA and any applicable accessibility guidelines, and further directing Defendant to send a copy of each quarterly report to Plaintiff’s counsel for review.
• An Order directing Defendant, by a date certain and at least once yearly thereafter, to provide mandatory web accessibility training to all employees who write or develop programs or code for, or who publish content to, the Website on how to
  conform all web content and services with ADA accessibility requirements and applicable accessibility guidelines;
• An award to Plaintiff of her reasonable attorney’s fees, costs and expenses.
• Such other and further relief as this Court deems just and equitable