DANIEL MONCADA V. HARLEY-DAVIDSON MOTOR COMPANY, INC.

• Mislabeled Links
• Content not presented in a way without losing information and structure;
• Missing description of images; and d. Site functions like reading text and sort options not interfacing with screen reader;
• Lack of Accessibility Notice.

Americans with Disabilties Act

• A declaration that Defendant’s Mobile Website is in violation of the ADA; 
• An Order requiring Defendant, by a date certain, to update the Mobile Website, and continue to monitor and update the Mobile Website on an ongoing basis, to remove barriers in order that individuals with visual disabilities can access, and continue to access, the Mobile Website and effectively communicate with the Mobile Website to the full extent required by Title III of the ADA;
• An Order requiring Defendant, by a date certain, to clearly display on the Mobile Website the universal disabled logo within the Website, wherein the logo1 would lead to a page which would state Defendant’s accessibility information, facts, policies, and accommodations. Such a clear display of the disabled logo is to insure that individuals who are disabled are aware of the availability of the accessible features of the Mobile Website;
• 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 providing for website accessibility feedback to insure 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 its Mobile Website;
• An Order directing Defendant, by a date certain, to establish a policy of web accessibility and accessibility features for the Mobile Website to insure 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 Mobile Website to be fully accessible to the visually disabled; 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 final content to, the Mobile Website on how to conform all web content and services with ADA accessibility requirements and applicable accessibility guidelines;
• An Order directing Defendant, by a date certain and at least once every three months thereafter, to conduct automated accessibility tests of the Mobile Website to identify any instances where the Mobile Website is no longer in conformance with the accessibility requirements of the ADA and any applicable accessibility guidelines, and further directing Defendant to send a copy of the twelve (12) quarterly reports to Plaintiff’s counsel for review;
• An Order directing Defendant, by a date certain, to make publicly available and directly link from the Mobile Website homepage, a statement of Defendant’s Accessibility Policy to ensure the persons with disabilities have full and equal enjoyment of the Mobile Website and shall accompany the public policy statement with an accessible means of submitting accessibility questions and problems;
• An award to Plaintiff of her reasonable attorney’s fees, costs and expenses; and
• Such other and further relief as the Court deems just and equitable.