Clay Lee Jones v. SMK ENTERTAINMENT GROUP, INC.

Case Summary

According to the complaint, Plaintiff CLAY LEE JONES, a visually impaired individual, alleges that SMK ENTERTAINMENT GROUP, INC. has failed to make its website, www.smokejazz.com, accessible to blind users, violating the Americans with Disabilities Act (ADA). Plaintiff claims that he encountered numerous barriers while attempting to purchase tickets for a live jazz show, including missing alt-text and broken links, which prevented him from accessing the services offered. The complaint seeks a permanent injunction to require the Defendant to comply with accessibility standards and to provide compensatory damages for the alleged discrimination.

Causes of Action

• Violations of the ADA, 42 U.S.C. § 12182 et seq.
• Violations of the NYCHRL
• Declaratory Relief

Key Allegations

• Defendant's website is not accessible to blind and visually impaired individuals.
• Plaintiff was denied the ability to purchase tickets due to website barriers.
• Defendant failed to comply with WCAG 2.1 guidelines.

Requested Relief

• Permanent injunction requiring Defendant to make its website accessible.
• Compensatory damages for violations of civil rights under New York City Human Rights Law.
• Attorney's fees and costs.

Proposed Class

All legally blind individuals in the United States who have attempted to access Defendant’s Website and as a result have been denied access to the equal enjoyment of goods and services, during the relevant statutory period.

Jurisdiction & Venue

This Court has subject-matter jurisdiction under 28 U.S.C. § 1331 and 42 U.S.C. § 12182, and venue is proper under 28 U.S.C. §1391(b)(1) and (2).